BIR Ruling No. 168-82
BIR Ruling No. 168-82 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • May 7, 1982
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May 7, 1982 BIR RULING NO. 168-82 24 (f) 121-82 168-82 C. Alcantara & Sons, Inc. P.O. Box 1602 FCS Makati, Metro Manila Attention: Ms . Editha I . Alcantara Senior Vice President Gentlemen : In reply to your letter dated March 16, 1982, please be informed that the 10% final withholding tax imposed by Section 24(f) of the Tax Code, as amended, on gross onshore income derived by the Foreign Currency Deposit Unit (FCDU) of the Citibank, N. A. on your foreign currency loan transaction with the said FCDU shall be based on the total or gross interest income paid to and received by the FCDU consisting not only of the spread but also of the stipulated, offered and prevailing rate of interest per loan agreement. Such being the case, your request for refund of an alleged over-payment of P912,868.94 has to be, as it is, hereby denied for lack of legal basis. Very truly yours, RUBEN B. ANCHETA Acting Commissioner
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