15% Withholding Tax — Cash Dividends

July 22, 1981 BIR RULING NO. 118-81 24-b-1 25-80 118-81 Basic Foods Corporation P.O. Box 1823 M a n i l a Attention: Mr . George K . Young Vice-President Gentlemen : This refers to your letter dated April 28, 1981 requesting a certification from this Office that the cash dividends which you will remit to your American shareholders, Universal Foods Corporation, at 433 East Michigan Street, Milwaukee, Wisconsin, USA is subject to withholding tax at the rate of 15%. It appears that the recipient corporation is a non-resident foreign corporation not engaged in trade or business in the Philippines owning 5,039,997 shares representing thirty percent (30%) of the outstanding capital stock of the Basic Foods Corporation. In view thereof, and considering that under the present provisions of the U.S. Federal Tax Code, the amount of tax deemed paid on such dividends, and accordingly, to be credited against U.S. tax on said dividends, meets the 20% requirement of Presidential Decree No. 369, this Office hereby certifies that the cash dividends which you will remit to Universal Foods Corporation domiciled in United States are subject to withholding tax at the rate of 15% only, pursuant to Section 24(b) (iii) of the Tax Code, as amended. aisadc Very truly yours, RUBEN B. ANCHETA Acting Commissioner