BIR Ruling

January 10, 1977 Smith Kline & French Victoria Valley), Inc. P. O. Box 229 Makati Commercial Center Makati, Metro Manila Gentlemen : This refers to your letter dated December 28, 1976 requesting certification from this Office that the dividends you will remit to Smith Kline & French International Co. is subject to withholding tax at the rate of 15%, instead of 35%. It appears that you are a domestic corporation; and that you are a wholly-owned subsidiary of Smith Kline & French International Co. which is a non-resident foreign corporation domiciled in the United States. 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 you will remit to Smith Kline & French International Co. domiciled in U.S. are subject to withholding tax at the rate of 15% only. (BIR Ruling No. 76-004 dated July 19, 1976) cdti Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-1456-040-3