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BIR Ruling

BIR Ruling • Bureau of Internal Revenue (BIR) Issuances • Rulings (Unnumbered) • Sep 30, 1975

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September 30, 1975 Hongkong and Shanghai Banking Corporation P.O. Box 1299, Commercial Center Makati, Rizal Gentlemen : In reply to your letter dated September 11, 1975, I have the honor to inform you that the dividends remitted by you to the Empire Finance Co. Ltd., Pembros Investment, Ltd., J.P.T. Securities Ltd., Tomafin, Ltd., and Pedder Ventures Ltd., non-resident foreign corporations domiciled in Hongkong, are subject only to the 15% withholding tax, prescribed by Section 24(b) of the Tax Code, as amended by Presidential Decree No. 369, it appearing that Hongkong does not impose any tax on income received by said corporations from foreign sources. aisa dc Very truly yours, (SGD.) EFREN I. PLANA Acting Commissioner of Internal Revenue TAN 1456-040-3

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