BIR Ruling

October 21, 1976 Sycip, Gorres, Velayo & Co. P.O. Box 589, Manila Attention: Mr . M . Gutierrez Tax Division Gentlemen : This refers to your letter dated July 24, 1976, requesting a certification from this Office that the dividends which your client, Muller and Phipps (Manila) Ltd., will remit to Muller and Phipps International, U.S.A., is subject to withholding tax at the rate of 15%, instead of 35%. cdta 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, 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 Muller and Phipps International, U.S.A., 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) 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."