BIR Ruling

January 16, 1974 Makati Stock Exchange Ayala Avenue Makati, Rizal Attention: Mr . Juan Francisco Gentlemen : This refers to your letter dated January 3, 1974, requesting information as to whether or not street certificates which are registered in the names of your member firms are subject to the 15% withholding tax prescribed by Section 24(d) of the Tax Code, as amended by Presidential Decree No. 299-A. You verbally represented that your member firms keep a record of street certificates wherein is indicated the actual beneficial owners thereof. You now propose that the 15% tax should not be withheld from the dividends on those shares belonging to individuals, and for purposes of identification and record, you manifested that member firms shall execute a sworn statement which they shall furnish to the stock transfer agents or secretaries of corporations, as the case may be, with a copy submitted to this Office showing the number of shares belonging to individuals and the number of shares belonging to corporations. In reply, I have the honor to inform you that your proposition is acceptable to this Office. This will serve as authority for your corporations to withhold the tax only on the dividends on the shares identified in your member-firms' sworn statements as belonging to corporations. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5