BIR Ruling
BIR Ruling • Bureau of Internal Revenue (BIR) Issuances • Rulings (Unnumbered) • Apr 5, 1977
Full text
April 5, 1977 Hongkong and Shanghai Banking Corporation P. O. Box 1299, Commercial Center Makati, Metro Manila Attention: Mr . R . Hardy Manager-Securities Gentlemen : In reply to your letters dated September 24 and November 29, 1976, I have the honor to inform you that it having been established that Hongkong does not impose any tax on dividends received by corporations domiciled thereon from foreign sources, the dividends remitted by you to Jardine Fleming & Co., Ltd. Hongkong and Commercial Investment Co., Ltd., non-resident foreign corporations domiciled in Hongkong, are subject only to the 15% withholding tax, prescribed by Section 24(b) of the Tax Code, as amended by Presidential Decree No. 369. (See Bir Ruling dated September 30, 1975) Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-P4519-F2828-A-8
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