BIR Ruling
BIR Ruling • Bureau of Internal Revenue (BIR) Issuances • Rulings (Unnumbered) • Aug 12, 1977
Full text
August 12, 1977 Schager Knitting, Inc. Rm. 602 Erechem Building Herrera cor. Salcedo St. Legaspi Village, Makati Metro Manila Attention: Mr . Felix C . Natividad Chief Accountant Gentlemen : This refers to your letter dated August 10, 1977, requesting that the interest to be remitted by you to Deutsche EntwicklungsGesellschaft (DEG) a German company for economic cooperation on account of a loan you obtained from it be declared exempt from the payment of income tax. In reply, I have the honor to inform you that it appearing from the certification of the Embassy of the Federal Republic of Germany that DEG is a private corporation but totally owned by the Federal Republic of Germany, the interest income of DEG on account of the loan extended to you is exempt from income tax, pursuant to Section 29(b)(7) of the Tax Code which exempt from a foreign government or from a financing institution owned, controlled, or enjoying refinancing from said foreign government. And as said interest is exempt from income tax, you need not comply with the provisions of Section 53(b)(2) of the Tax Code. This will serve as the certification required of by the Central Bank. Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-P4519-F2828-A-8
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