BIR Ruling No. 025-80

October 20, 1980 BIR RULING NO. 025-80 24(b)(1) (iii) 76-004 25-80 Messrs. Ozaeta, Romulo, De Leon, Mabanta, Buenaventura, Sayoc & De los Angeles Second Floor, Corinthian Plaza 121 Paseo de Roxas, Makati, Metro Manila Attention : Atty . Exequiel B . Javier Gentlemen: This refers to your letter dated June 26, 1980 requesting a certification from this Office that the dividends your client, Twentieth Century-Fox (Philippines), Inc. will remit to Twentieth Century Fox International Corporation (Fox International) is subject to withholding tax at the rate of 15% instead of 35%. It appears that your client is a domestic corporation, more than 90% of the outstanding stock of which is owned by the aforenamed recipient corporation and that the latter is a non-resident foreign corporation domiciled in the United States. In view thereof, and considering that under the present provisions of the U.S. Federal Tax Code, the amount of tax deemed paid on such dividends, and accordingly, to be credited against U.S. tax on said dividends, meets the 20% requirement of Presidential Decree No. 369, this Office hereby certifies that the dividends which your client will remit to Twentieth Century-Fox International Corporation (Fox International) domiciled in U.S. are subject to withholding tax at the rate of 15% only. cdti Very truly yours, ROMULO M. VILLA Acting Commissioner