BIR Ruling

December 8, 1976 Singer Industries, Philippines, Inc. P. O. Box 1241 MCC, Makati, Rizal Attention: Mr . F . M . Abeleda, Jr . Controller Gentlemen : This refers to your letter dated November 16, 1976, requesting a certification from this Office that the dividends which Singer Industries, Philippines, Inc. will remit to International Securities Co., is subject to withholding tax at the rate of 15%, instead of 35%. It appears that Singer Industries, Philippines, Inc. is a domestic corporation; it is a wholly-owned subsidiary of the aforenamed recipient corporation; and that said corporation is a non-resident foreign corporation domiciled in U.S. In view thereof, and considering that under the present provisions of the U.S. Federal Tax Code, the amount of tax deemed paid on such dividends, and accordingly, to be credited against U.S. tax on said dividends, exceeds the 20% requirement of Presidential Decree No. 369, this Office hereby certifies that the dividends which Singer Industries, Philippines, Inc. will remit to International Securities Co., domiciled in U.S. are subject to withholding tax at the rate of 15% only. (B.I.R. Ruling No. 76-004 dated July 19, 1976) Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-1456-040-3 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."