BIR Ruling No. 022-82

January 26, 1982 BIR RULING NO. 022-82 24-cc 000-00 022-8200 Philippine Associated Smelting and Refining Corporation 3rd Floor Bancom III Bldg. Rada and Legaspi Streets Legaspi Village, Makati Metro Manila Attention: Mr . B . C . Antonio, Jr . Controller Gentlemen : This refers to your letter dated January 16, 1981, requesting exemption from the withholding tax on the interest income of your bank deposits and deposit substitutes imposed under Presidential Decree No. 1739. In reply, I regret to inform you that your request cannot be granted for lack of legal basis. Under the certification issued to you on October 10, 1980, by the Board of Investments pursuant to Republic Act No. 6135, you are exempt from the payment of all taxes under the National Internal Revenue Code, except income tax (See Also Sec. 7 of Republic Act No. 6135, in relation to Sec. 8 of Republic Act No. 5186). The interest earnings of your bank deposits and money market placements are considered income and the withholding tax imposed thereon is income tax to which you are still liable as a BOI registered enterprise. Such being the case, you are subject to the 15% final withholding tax, in case of savings deposits, and 20% in case of time deposits and yields from deposit substitutes imposed by Section 24(cc) of the Tax Code, as amended by Presidential Decree No. 1739. aisadc Very truly yours, RUBEN B. ANCHETA Acting Commissioner