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BIR Ruling No. 123-82

BIR Ruling No. 123-82 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Apr 16, 1982

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April 16, 1982 BIR RULING NO. 123-82 024-(b) 080-80 123-82 Jardine Manila Finance, Inc. Jardine Davies Bldg. 222 Buendia Avenue Makati, Metro Manila Attention: Mr . Jesus P . Lukban Corporate Secretary Gentlemen : In reply to your letter dated November 10, 1978, I have the honor to inform you that it having been established that HongKong does not impose any tax on dividends received by corporations domiciled therein from foreign sources, the dividends to be remitted by Jardine-Manila Finance, Inc. to Jardine-Barclays, Ltd., a non-resident foreign corporation domiciled in HongKong are subject only to the 15% withholding tax, prescribed by Section 24(b)(l)(iii) of the Tax Code, as amended. Very truly yours, RUBEN B. ANCHETA Acting Commissioner

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