BIR Ruling No. 139-83

August 2, 1983 BIR RULING NO. 139-83 Gentlemen : This refers to your letter dated June 30, 1983 requesting a ruling that dividends to be paid by your company to Saztec (Australia) Superannuation Fund Pty. Ltd. Australia, a resident of Australia is subject to 15% withholding tax only pursuant to the RP-Australia Tax Treaty. In reply, please be informed that under Art. 10,(1)(a) of the RP-Australia Tax Treaty, the withholding tax on dividends derived by an Australia company is 15% of the gross amount of the dividend where relief either by way of rebate or credit described in paragraph (2) of Article 24 of the said Tax Treaty is given to the beneficial owner of the dividends. casia Considering that as per letter of Deputy Commissioner of Taxation of the Australian Taxation Office, Saztec (Australia) Pty. Ltd. Superannuation Fund, the recipient of the said dividends, has complied with the requirements of Section 23 F of the Australian Income Tax Assessment Act, thereby making it exempt from income tax in Australia, the Philippine withholding tax on dividends remitted to that company is only 15% of the gross amount thereof. Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue