BIR Ruling

September 26, 1973 Marsteel Corporation 8th Floor, CIBA Building 666 T.M. Kalaw Street Ermita, Manila Gentlemen : This refers to your letter dated September 19, 1973, wherein you informed this Office that under your loan agreement with your non-resident creditors you are primarily and solely liable for payment of all taxes that may be due on interests payable to said creditors. Under the aforesaid facts you would like to be advised whether you are entitled to the benefits of Presidential Decree No. 23, as amended, if you declared in an amnesty tax return the interest remitted by you to your non-resident creditors and paid 10% on said interests. In reply, I have the honor to inform you that if, as represented, you are, under the loan agreement with your non-resident creditors, the one liable for taxes on the interests to be paid to your non-resident creditors, your payment of 10% tax on said interests as prescribed in Presidential Decree No. 23, as amended, shall entitle you to all privileges and immunities provided for in said decree. acd Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5