There's a US–Philippines tax treaty — does it stop US tax?

No. The treaty is in force (general effect 1 January 1983), but Article 6(3) is a saving clause: the US may tax its citizens and residents as if the treaty were not there. The treaty narrows double tax; it does not cancel your US return, FBAR, or Form 8938.

Does the Philippines tax my US salary or pension if I live there?

Aliens are taxed only on Philippine-source income under NIRC §23(D). Remitting money into a Philippine bank does not by itself create Philippine tax. Source turns on where services were performed. Separately, treaty Article 18 taxes private pensions for past employment in the state where that service was rendered — different from the US–Thailand residence-only rule.

How is Social Security taxed between the two?

Treaty Article 19: social security and similar public pensions are taxable only in the paying state. That article is an exception to the saving clause (Art 6(4)), so it actually binds. There is still no SSA totalization agreement with the Philippines — contribution coordination is a separate gap.

Do I still get a credit for Philippine tax?

Yes. Article 23 (relief from double taxation) is an exception to the saving clause, so a US citizen keeps the foreign tax credit for Philippine income tax on double-taxed income.

United States → Philippines · tax

In plain termsTwo true sentences at once: there is a treaty, and a US citizen still files a US return. On the Philippine side, aliens remain Philippine-source only — not a remittance trap.

There is a treaty

An in-force US–Philippines income tax convention exists (yes), general effective date 1 January 1983. Dual residence uses the Art 3 cascade: permanent home → centre of vital interests → habitual abode → citizenship.

But the saving clause stays

Client trapArticle 6(3) is a saving clause (yes): the US taxes its citizens as if the treaty were not in force. Citizenship-based taxation (yes), FBAR above 10000 USD, Form 8938 (yes), and FEIE's 330 days physical-presence test all survive.

Philippine side — source, not remittance

Under NIRC §23(D), aliens are taxed only on Philippine-source income (yes). There is no remittance basis (yes). See the Philippines tax pillar.

Where the treaty actually bites

Private pension — taxable where the past employment was performed (yes, Art 18(1)). This is not the US–Thailand residence-only rule.
Social security — taxable only in the paying state (yes, Art 19, saving-clause exception).
Foreign tax credit — preserved for US citizens (yes, Art 23).
Totalization — none (no). Contribution coordination is a separate gap from the income-tax treaty.

An in-force US–Philippines income tax treaty exists
US–Philippines Income Tax Convention, signed Manila 1 Oct 1976; entered into force 16 Oct 1982 (irs.gov/pub/irs-trty/philip.pdf)
yeschecked Aug 2026
General effective date of the US–Philippines income tax treaty
US–Philippines Convention Art 29 — general effective date 1 January 1983
1 January 1983checked Aug 2026
Saving clause: the treaty does not switch off US tax on US citizens
US–Philippines Convention Art 6(3) — a Contracting State may tax its residents and citizens as if the Convention had not come into effect (exceptions Art 6(4))
yeschecked Aug 2026
Treaty Art 3 tie-breaker for US–Philippines dual residence
US–Philippines Convention Art 3(2) dual-residence tie-breaker cascade
permanent home → centre of vital interests → habitual abode → citizenshipchecked Aug 2026
Private pensions are taxable where the past employment was performed (not residence-only)
US–Philippines Convention Art 18(1) — pensions for past employment taxable by the Contracting State where the service is rendered
yeschecked Aug 2026
Social security is taxable only in the paying state (saving-clause exception)
US–Philippines Convention Art 19 — social security/public pensions taxable only in the paying State; Art 6(4) saving-clause exception
yeschecked Aug 2026
Treaty preserves the foreign tax credit for double-taxed income
US–Philippines Convention Art 23 — relief from double taxation by foreign tax credit; Art 6(4) exception to the saving clause
yeschecked Aug 2026
A US–Philippines social security totalization agreement exists
SSA — U.S. International Social Security (Totalization) Agreements list does not include the Philippines
nochecked Aug 2026
US taxes citizens on worldwide income regardless of residence
US domestic rule (citizenship-based taxation) — independent of the PH treaty; preserved by Art 6(3) saving clause
yeschecked Aug 2026
FBAR aggregate foreign-account threshold
IRS FBAR — aggregate foreign financial accounts exceeded $10,000 at any time during the calendar year
10000 USDchecked Aug 2026
FEIE physical-presence limb
IRS FEIE — physical presence test: at least 330 full days in a foreign country during any 12 consecutive months (Form 2555)
330 dayschecked Aug 2026
Form 8938 (FATCA specified foreign financial assets) exists
IRS — Form 8938 Statement of Specified Foreign Financial Assets (FATCA)
yeschecked Aug 2026

Philippines tax pillar
Contrast: US → Thailand · tax · US → Vietnam · tax

Common questions

There's a US–Philippines tax treaty — does it stop US tax?: No. The treaty is in force (general effect 1 January 1983), but Article 6(3) is a saving clause: the US may tax its citizens and residents as if the treaty were not there. The treaty narrows double tax; it does not cancel your US return, FBAR, or Form 8938.
Does the Philippines tax my US salary or pension if I live there?: Aliens are taxed only on Philippine-source income under NIRC §23(D). Remitting money into a Philippine bank does not by itself create Philippine tax. Source turns on where services were performed. Separately, treaty Article 18 taxes private pensions for past employment in the state where that service was rendered — different from the US–Thailand residence-only rule.
How is Social Security taxed between the two?: Treaty Article 19: social security and similar public pensions are taxable only in the paying state. That article is an exception to the saving clause (Art 6(4)), so it actually binds. There is still no SSA totalization agreement with the Philippines — contribution coordination is a separate gap.
Do I still get a credit for Philippine tax?: Yes. Article 23 (relief from double taxation) is an exception to the saving clause, so a US citizen keeps the foreign tax credit for Philippine income tax on double-taxed income.