15% withholding Tax — Non-Resident Foreign Corporations

February 15, 1980 BIR RULING NO. 030-80 Messrs. Sycip, Gorres, Velayo & Co. P.O. Box 589, Manila 2800 Attention: Mr . J . U . Ong Tax Division Gentlemen : In reply to your letter dated February 6, 1980, I have the honor to inform you that it having been established that Switzerland does not impose any tax on dividends received from foreign sources, the dividends to be remitted by your client, Alcon Laboratories Philippines, Inc., to Nestle, S.A. or through its nominee, Alcon Universal Ltd., both non-resident foreign corporations domiciled in Switzerland, are subject to withholding tax at the rate of 15% only, in accordance with Section 24(b)(1)(iii) of the Tax Code of 1977, as amended. (See BIR Ruling dated May 31, 1977). Very truly yours, RUBEN B. ANCHETA Acting Commissioner