Allowable Income Tax Deduction Granted to Shell Company

February 11, 1958 BIR RULING NO. 094-58 MEMORANDUM FOR The Chief, Income Tax Division Bureau of Internal Revenue Manila (Thru the Revenue Operations Executive [Assessment]) In connection with the question of whether or not the Shell Company of the Philippines, Ltd., a resident foreign corporation is entitled to deduct income taxes paid to the United Kingdom on income derived from sources within the Philippines, it is the opinion of this Office that said corporation has a right to deduct the income tax paid to the British Government under the authority of Section 30(c)(1)(B) of the National Internal Revenue Code. cdll Recently, this Office allowed the deduction of income tax paid to the Federal Government by the Kodak Philippines, Ltd. for the year 1950. Accordingly, appropriate action should be taken on the herein case. (SGD.) JOSE ARAAS Commissioner of Internal Revenue