BIR Ruling

May 31, 1977 Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accountants 6760 Ayala Avenue, Makati Rizal Attention: Atty . M . Gutierrez Tax Division Gentlemen : This refers to your letter dated February 19, 1977 requesting confirmation that the dividends to be remitted by your client, Filipro, Inc., to its two nonresident foreign corporate stockholders, Itag A. G. and Investrade A. G., both Swiss companies not doing business in the Philippines, are subject to withholding tax at the rate of 15% only, pursuant to Presidential Decree No. 369. In support of your stand that the dividends in question are subject to 15% withholding tax, you submitted the following documents: (1) Xerox copy of the Certification of the Tax Office at Zurich that the dividends payable to Itag SA by Filipro, Inc. are exempt from Swiss Federal Tax, duly authenticated by the Philippine Consular Official at Berne, Switzerland; and (2) Xerox copy of the Certification that the dividends payable to Investrade SA by Filipro, Inc. are exempt from Swiss Federal Tax, duly authenticated by the Philippine Consular Office at Berne, Switzerland. In reply, I have the honor to inform you that it appearing that Switzerland, the domicile of the recipient companies, does not impose any income tax on dividends received by corporations therein from sources outside said country, the dividends to be remitted by your client to the abovenamed non-resident foreign corporations are subject to withholding tax at the rate of 15% only. cdti Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-P4519-F2828-A-8