BIR Ruling

January 10, 1977 Joaquin Cunanan & Co. 8th Floor, Rufino Bldg. 6784 Ayala Avenue Makati, Rizal Gentlemen : This refers to your letter dated December 29, 1976 requesting certification from this Office that the dividends which your client, Sumak Realty Corporation, will remit to Firestone Tire & Rubber Co., is subject to withholding tax at the rate of 15%, instead of 35%. It appears that your client is a domestic corporation, 40% of the total stockholdings of which is owned by Firestone Tire & Rubber Co., a non-resident foreign corporation domiciled in the United States. cdta In view thereof, and considering that under the present provisions of the U.S. Federal Tax Code, the amount of tax deemed paid on such dividends, and accordingly, to be credited against U.S. tax on said dividends, exceeds the 20% requirement of Presidential Decree No. 369, this Office hereby certifies that the dividends which your client will remit to Firestone Tire & Rubber Co. domiciled in U.S. are subject to withholding tax at the rate of 15% only. (BIR Ruling No. 76-004 dated July 19, 1976) Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-1456-040-3