BIR Ruling No. 178-82

May 19, 1982 BIR RULING NO. 178-82 024-cc 000-00 178-82 Land Bank of the Philippines 6th Floor, BF Condominium Bldg. Intramuros, Manila Attention: Mr . A . B . F . Gaviola, Jr . Acting Trust Officer Gentlemen : This refers to your letter dated January 8, 1981 in behalf of Food Terminal Inc. (FTI) requesting a certification from this Bureau as to the tax-exempt status of FTI, pursuant to Letter of Instructions No. 1013, dated April 19, 1980, for the purpose of exemption from the withholding tax provision of Section 53(e) of the Tax Code, as amended by Presidential Decree No. 1739 and implemented by Rev. Regs. No. 12-80. In reply, please be informed that since the Food Terminal Inc. is exempt from the payment of income taxes pursuant to Section 10 of LOI No. 1013, its interest income shall be exempt from the 15% final withholding tax in the case of savings deposit and 20% in the case of time deposit and yield from deposit substitute (e.g. money market transaction) prescribed by Section 24(cc) in relation to Section 53(e) of the Tax Code, as amended. The FTI is not covered by Presidential Decree No. 1177, which requires government-owned or controlled corporations to pay income taxes effective July 30, 1977, since LOI No. 1015 was promulgated after said date. cdta This serves as authority of the depository banks to forego withholding of the tax on the interest earnings of the deposits maintained by FTI with them. Very truly yours, RUBEN B. ANCHETA Acting Commissioner