Rental Payment on the Computer Machine to be Paid by Gets Corporation Phil., Inc. to Its U.S. Lessor Abroad shall be Subject to 7 1/2% Withholding Tax

August 26, 1980 BIR RULING NO. 117-80 Messrs. Sycip, Gorres, Velayo & Co. P. O. Box 589, Manila Attention: Mr . M . Gutierrez Tax Division Gentlemen : This refers to your request for confirmation of your opinion to the effect that the rental payment on the lease of a computer machine (IBM Systems 34) which will be paid by your client, Gets Corporation Philippines, Inc. to its U.S. lessor shall be subject to a 7 1/2% withholding tax. It is represented that your client is contemplating to lease from U.S. company abroad, a non-resident foreign company not doing business in the Philippines, a computer machine (IBM Systems 34) subject to a rental payment as may be agreed upon. In reply thereto, I have the honor to inform you that the rental payment on the computer machine to be paid by Gets Corporation Philippines, Inc. to its U.S. lessor abroad shall be subject to 7 1/2% withholding tax pursuant to Section 24(b)(vii) in relation to Sections 53 and 54 both of the Tax Code, as amended. Very truly yours, TOMAS C. TOLEDO Acting Commissioner