BIR Ruling

December 4, 1973 MEMORANDUM FOR: The Chief, Services and Miscellaneous (Audit) Division There is referred to you the letter dated November 20, 1973 of the Law Office of Cruz, Villarin, Ongkiko, Academia & Durian protesting against the investigation being conducted by that Division on the withholding tax liabilities of its client, General Textiles, Inc. for the years 1960 to 1967. The withholding tax liabilities are based foreign suppliers-creditors. In the within letter, the taxpayer, thru counsel, invokes as a defense that it availed of the amnesty under Presidential Decrees Nos. 23 and 157. If the taxpayer as withholding agent, declared in its amnesty return the entire remitted interest income to the non-resident foreign suppliers-creditors and not merely the withholding tax due thereon and payable, and paid 10% of said interest income, the taxpayer is relieved from any administrative, civil, or criminal liabilities under the National Internal Revenue Code, on the said remitted interest income. cdt Be guided accordingly. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."