BIR Ruling

September 13, 1977 Atty. Antero M. Sison, Jr. 6th Floor, Rufino Building 6784 Ayala Avenue, Makati Metro Manila S i r : This refers to your letter dated July 15, 1977, requesting on behalf of your client, Adams Brands, Inc. a certification to the effect that the cash dividends that said corporation will remit to its parent company, Warner-Lambert Company, a non resident U.S. corporation domiciled in Delaware, U.S.A., are subject to withholding tax at the rate of 15% only. In reply, I have the honor to inform you it appearing from the evidence submitted by you that your client, Adams Brands, Inc. is a wholly owned subsidiary of Warner-Lambert Company, a nonresident U.S. corporation, and considering that under the present pertinent provisions of the U.S. Federal Tax Code, the amount of tax deemed paid and to be credited against the U.S. tax on the dividends received by the U.S corporation from your client exceeds the 20% requirement of Presidential Decree No. 369 (BIR Ruling No. 76-004 dated July 19, 1976), this Office hereby certified that the cash dividends to be remitted by your aforementioned client to Warner-Lambert Company, Delaware, U.S.A., are subject to withholding tax at the rate of 15% Only. Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-P4519-F2828-A-8 "TAXPAYER SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."