BIR Ruling

October 21, 1976 Messrs. Sycip, Gorres, Velayo & Co. P. O. Box 589 Manila Attention: Mr . B . V . Abela Tax Division Gentlemen : This refers to your letter dated August 2, 1976, requesting a certification from this Office that the dividends which your client, Goodyear Tire and Rubber Company of the Philippines, Ltd. will remit to Goodyear Tire & Rubber Co. is subject to withholding tax at the rate of 15%, instead of 35%. It appears that your client is a domestic corporation; that it is wholly owned by 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 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 369, this Office hereby certifies that the dividends which your client will remit to Goodyear Tire & Rubber Co., domiciled in U.S. is subject to withholding tax at the rate of 15%, instead of 35%. (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."