BIR Ruling [DA-254-96]

July 18, 1996 BIR RULING [DA-254-96] Phil. Export & Foreign Loan Guarantee Corp. 5th Floor, Executive Building Center Sen. Gil Puyat Ave., cor. Makati Avenue Makati City Attention: Mr . Jesus M . Taedo Executive Vice-President S i r : This refers to your letter dated June 18, 1996 requesting for a certification to the effect that you are not subject to the expanded withholding tax (EWT) under Revenue Regulations No. 12-94. In reply, please be informed that pursuant to Section 3 of Revenue Regulations No. 12-94, amending Section 4 of Revenue Regulations No. 6-85, stating "SEC. 4. Exemption from Withholding . The withholding of tax prescribed in these regulations shall not apply to income payments in the following cases: "(a) Income payments to the national government and its instrumentalities, including provincial, city or municipal governments, as well as government-owned or controlled corporations; . . ." (Emphasis supplied) your opinion that as a government-owned or controlled corporation, you are not subject to the creditable expanded withholding tax prescribed under Revenue Regulations No. 12-94, is hereby confirmed. (BIR Ruling No. 117-95 dated July 31, 1995) This serves as your certification that income payments to you are not subject to the expanded withholding tax. cdtech Very truly yours, ALICIA P. CLEMENO Assistant Commissioner (Legal Service) By: ALICIA L. TOMACRUZ Head Rev. Executive Assistant Legal Service