BIR Ruling No. 046-83
BIR Ruling No. 046-83 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Mar 21, 1983
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March 21, 1983 BIR RULING NO. 046-83 Gentlemen : This refers to your letter dated February 2, 1982 on behalf of your client, HONGKONG AND SHANGHAI BANKING CORPORATION (HSBC) requesting a ruling to the effect that dividends payable by your client to Wayhong (NH) Ltd., a foreign corporation domiciled in the Republic of Vanuatu, are subject to the rate of 15% withholding tax under Section 24(b) (1)(iii) of the Tax Code, as amended. In reply, please be informed that it having been established that the Republic of Vanuatu, formerly New Hebrides, is a "no tax" haven and therefore, does not impose any tax on dividends received by corporations domiciled therein from foreign sources the dividends to be remitted by your client to Wayhong (NH) Ltd., are subject only to 15% withholding tax prescribed by Section 24(b)(1)(iii) of the Tax Code, as amended. Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue
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