Final Withholding Tax of 7 1/2 % — Non-Resident Foreign Corporation

August 6, 1981 BIR RULING NO. 148-81 24-b 014-81 148-81 Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accounts 6760 Ayala Avenue, Makati Attention: Mr . J . U . Ong Tax Division Gentlemen : This refers to your letter dated March 23, 1981 requesting a ruling as to the correct rate of withholding tax due from your client, the DART INDUSTRIES (PHILIPPINES), INC. on rentals of steel molds being paid by it to a non-resident corporation. It is represented that your client is engaged in the manufacture of tupperware products; that steel molds are indispensable pieces of equipment in said manufacture; and that your client pays rentals on the said equipment under a lease agreement with a non-resident foreign corporation. In reply, I have the honor to inform you that the rentals due to the non-resident foreign corporation on the lease of the above equipment are subject to a final withholding tax of 7 1/2 %, pursuant to Section 24 (b)(1)(vii) of the Tax Code, as amended. cdtech Very truly yours, RUBEN B. ANCHETA Acting Commissioner