BIR Ruling

September 5, 1977 Atty. Antero M. Sison, Jr. 6th Floor, Rufino Building 6784 Ayala Avenue, Makati Metro Manila S i r : This refers to your request for certification to the effect that the cash dividend which your client, Warner-Chilcott Laboratories (Phil), Inc., will remit to Warner Lambert Company, a U.S. corporation domiciled in Delaware, U.S.A., is subject to withholding tax at the rate of 15% only, pursuant to Section 24(b)(1) of the Tax Code, as amended by Presidential Decree No. 369, in relation to Sections 53 and 54 of the said Code. In reply, I have the honor to inform you that the cash dividend to be remitted by your client, a wholly owned subsidiary of the said nonresident U.S. corporation, to its parent company is subject to the withholding tax at the rate of 15%, it appearing that under the present and 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 dividend received by the U.S. corporation from your client exceeds the 20% requirement of Presidential Decree No. 369. (BIR Ruling No. 76-004 dated July 19, 1976) Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-P4519-F2828-A-8