BIR Ruling No. 113-84

June 29, 1984 BIR RULING NO. 113-84 24-b-000-00-113-84 Gentlemen : This refers to your letter dated February 29, 1984 requesting confirmation that Michigan Investments Limited Nassau a company incorporated in the City of Nassau, Commonwealth of the Bahamas, is entitled to the reduced 15% withholding tax on dividends received from domestic corporation, pursuant to Section 24, (b), (1), (iii) of the Tax Code, as amended. It is represented that your client Michigan Investments Limited Nassau is a non-resident corporation domiciled in the Commonwealth of Bahamas and said company derived cash dividends from their investments in the Philippines. Considering that it has been established that the Commonwealth of Bahamas does not impose any tax on dividend income received by corporations domiciled therein from foreign sources, the dividends from sources within the Philippines remitted to Michigan Investments Limited Nassau, shall, pursuant to Section 24, (b), (1), (iii) of the Tax Code, be subject only to 15% withholding tax. iatdc Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner