15% Withholding Tax — Non-Resident Foreign Corporation
BIR Ruling No. 080-80 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jun 18, 1980
Full text
June 18, 1980 BIR RULING NO. 080-80 The HongKong and Shanghai Banking Corporation P.O. Box 1299 Commercial Centre, Makati, Metro Manila Attention: Mr . A . R . Servinio Manager-Securities Gentlemen : In reply to your letters dated April 8 and May 5, 1980, I have the honor to inform you that it having been established that HongKong does not impose any tax on dividends received by Corporations domiciled therein from foreign sources, the dividends remitted by you to Bermuda Trust (Far East) Limited, a non-resident foreign corporation domiciled in HongKong, are subject only to the 15% withholding tax prescribed by Section 24(b)(1)(iii) of the Tax Code, as amended. (See B.I.R. Ruling No. 010-80 dated February 5, 1980). cdta Very truly yours, RUBEN B ANCHETA Acting Commissioner
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