BIR Ruling No. 151-82

April 27, 1982 BIR RULING NO. 151-82 053-e 000-00 151-82 Philippine Deposit Insurance Corporation Makati, Metro Manila Attention: Mr . Luis Tirso Rivilla Chairman Gentlemen : This refers to your letter dated September 18, 1979 requesting exemption from the withholding tax on interests on bank deposits and on all other income of that Corporation. In reply, please be informed that under your Charter (Republic Act No. 3591, as amended), you are not exempt from the payment of income tax. Consequently, your interest earnings from bank deposits are subject to the final tax on the total amount thereof at the rate of 15% in the case of savings deposit and 20% in the case of time deposits, in accordance with Section 24(cc) of the Tax Code, as amended by P.D. No. 1739. Said tax shall be deducted and withheld by the bank, in accordance with Section 53(e) of the same Code. In this connection, it should be noted that the tax on interest on bank deposits is imposed under Section 24, in relation to Section 53, both of the Tax Code. On the other hand, the withholding of tax on other income of that Corporation is governed by Presidential Decree No. 1351 which amended Section 53(f) of the same Code and implemented by Revenue Regulations No. 13-78, as amended by Revenue Regulations No. 6-79. However, such other income of the Corporation falling under the enumeration of Revenue Regulations No. 15-78, as amended, shall be exempt from withholding pursuant to Section 4 thereof which exempts from withholding tax income payments to government-owned or controlled corporations such as that corporation. In other words, Revenue Regulations No. 13-78, as amended, does not apply to your interest income on bank deposit and, therefore, said interest income cannot be exempted from the requirements of withholding of tax on the basis of Section 4 of said regulations. aisadc Very truly yours, RUBEN B. ANCHETA Acting Commissioner