15% Withholding Tax — Non-resident Foreign Corporation
BIR Ruling No. 136-81 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jul 30, 1981
Full text
July 30, 1981 BIR RULING NO. 136-81 24-b 000-77 136-81 Law Offices Siguion Reyna, Montecillo and Ongsiako A. Soriano Bldg. Ayala Avenue, Makati Attention: Atty . Hector Martinez Gentlemen : In reply to your letter dated July 8, 1981, I have the honor to inform you that having been established that Panama does not impose any tax on dividends received from foreign sources, the dividends to be remitted by your client, Bristol Laboratories (Philippines), Inc., a Philippine Corporation, to its parent company, Bristol Laboratories International, S.A., a non-resident foreign corporation organized under the laws of, and domiciled, in Panama, are subject to withholding tax at the rate of 15% only, in accordance with Section 24(b)(1)(iii) of the Tax Code. Very truly yours, RUBEN B. ANCHETA Acting Commissioner
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