BIR Ruling No. 121-82

April 16, 1982 BIR RULING NO. 121-82 24 (f) 000-00 121-82 Asia Brewery Incorporated 4th Floor, Allied Bank Center 6754 Ayala Avenue, Makati Metro Manila Attention: Mr . Domingo T . Chua Director Gentlemen : This refers to BIR Ruling No. 24-f-000-00-214-81 dated November 6, 1981 holding that the 10% withholding tax imposed by Sec. 24(f) of the Tax Code on gross onshore income derived by the Foreign Currency Deposit Unit (FCDU) on your foreign currency loan transaction with the said FCDU shall be based only on interest income consisting of the spread of 1 %. In connection therewith, please be informed that based on the facts subsequently gathered by this Office, which are materially different from those upon which the aforesaid ruling was based, our final conclusion is that the gross interest income that is subject to the 10% withholding tax consists of the spread of 1 %, the London Interbank offered rate (Libor) and the margin of 1%. This is the total or the gross onshore income paid to and received by the FCDU. This revokes BIR Ruling No. 24-f-000-00-214-81 dated November 6, 1981. aisadc Very truly yours, RUBEN B. ANCHETA Acting Commissioner