Dividends Received by Drexel Burnham Lambert, Inc. from San Miguel Corp. Subject to 15% Tax

March 22, 1985 BIR RULING NO. 045-85 24-b 126-83 045-85 Dear Sir : This refers to your letter dated January 25, 1985 requesting for a confirmation that the cash dividends issued by a Philippine corporation in favor of your client, Drexel Burnham Lambert, Inc. is subject to the reduced 15% withholding tax pursuant to Section 24(b)(1)(iii) of the Tax Code. It is represented that Drexel Burnham Lambert, Inc. is a HongKong based company and that it derived dividends from San Miguel Corporation, a Philippine corporation. Considering that it has been established that HongKong does not impose tax on dividend income received by corporations domiciled therein from foreign sources, the dividends received by Drexel Burnham Lambert, Inc. from San Miguel Corporation shall be subject to 15% tax pursuant to Section 24(b)(1)(iii) of the Tax Code. cdti Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner