BIR Ruling

October 27, 1976 Sycip, Gorres, Velayo & Co. P. O. Box 589, Manila Attention: Mr . B . V . Abela Tax Division Gentlemen : This refers to your letter dated August 9, 1976, requesting a certification from this Office that the dividends which your client, USI-Asia Pacific, Inc., will remit to USI International 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, exceeds the 20% requirement of Presidential Decree No. 369, this Office hereby certifies that the dividends which your client will remit to USI International, 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) aisa dc 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."