BIR Ruling

November 16, 1977 2236 Realty Co., Inc. 2236 Pasong Tamo St. Makati, Metro Manila Attention: Mr . Crispin A . Rivera, Jr . Finance Manager Gentlemen : This refers to your letter dated August 24, 1977 requesting a certification to the effect that the dividends requesting payable by you, a domestic corporation, to American Home Products Corporation (AHPC), nonresident U.S. corporation, are subject only to 15% withholding tax, pursuant to Section 24(b)(1) of the Tax Code, as amended by Presidential Decree No. 369. In reply, I have the honor to inform you, that it appearing from the evidence presented by you that American Home Products Corporation (AHPC) owns 40% of your subscribed and paid-up capital stock, and considering that under the pertinent provisions of the U.S. Federal Tax Code, the amount of tax deemed paid and to be credited against the U.S. tax on the dividends received by the U.S. corporation exceeds the 20% requirement of Presidential Decree No. 369 (BIR Ruling No. 76-004) dated July 19, 1976), this Office hereby certifies that the cash dividends payable by you to American Home Products Corporation, a nonresident U.S. corporation, are subject to withholding tax at the rate of 15% only. This letter will serve as the confirmation required by the Central Bank in connection with your remittance of dividends to the American Home Products Corporation. Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-P4519-F2828-A-8