BIR Ruling No. 016-80

September 24, 1980 BIR RULING NO. 016-80 024-b2 000-00 16-80 Dow Chemical Pacific Limited National Life Bldg., Makati, Metro Manila Attention : Mr . Robert I . Anderson Resident Manager Gentlemen: This refers to your letter dated May 19, 1980 requesting a ruling as to whether the repatriation of the foreign exchange equivalent of P1,306,501.00 to your Head Office in HongKong, representing retained earnings of the Philippine branch as of December 31, 1977 which were converted in 1978 into assigned capital of your Head Office and duly registered as foreign investment by the Central Bank of the Philippines is subject to tax. In reply thereto, I have the honor to inform you that the repatriation of the retained earnings of the Philippine branch in the amount of P1,306,501.00 as of December 31, 1977 which were converted in 1978 into assigned capital of the head office is subject to the 15% branch profit remittance tax pursuant to Section 24(b)(2) of the Tax Code, as amended. Very truly yours, RUBEN B. ANCHETA Acting Commissioner