Dividends to be Remitted to Berlhest Company Ltd. Subject to the 15% Withholding Tax
BIR Ruling No. 009-85 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jan 21, 1985
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January 21, 1985 BIR RULING NO. 009-85 24-b 000-00 009-85 Gentlemen : This refers to your letter dated December 3, 1984 requesting a certification that the dividends which your company, Berlei Hestia Philippines, Inc. will remit to Berlhest Company Ltd., a Diechtenstein corporation, is subject to 15% withholding tax. It is represented that Berlhest Company Ltd. is a non-resident corporation domiciled in Diechtenstein; that it derived dividends from its investments in the Philippines; and that said company has no obligation to pay any income tax in Diechtenstein as long as it has the privileged status of holding company. In reply, please be informed that it having been established that Berlhest Company Ltd. will not be subject to tax on its dividends from Philippine sources, the dividends to be remitted to Berlhest Company Ltd. are subject to the 15% withholding tax prescribed by Sec. 24(b)(i)(iii) of the National Internal Revenue Code. cdtech Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner
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