BIR Ruling No. 179-83

October 11, 1983 BIR RULING NO. 179-83 Gentlemen : This refers to your letter dated February 3, 1983 requesting a ruling as to whether the interest payments of Canlubang Automotive Service Corporation (CASCO) to Canlubang Automotive Resources Corporation (CARCO) on a loan agreement executed between them is subject to the expanded withholding tax. In reply, I have the honor to inform you that under Revenue Regulations No. 13-78, as amended by Revenue Regulations No. 6-79, implementing Presidential Decree No. 1351, now Section 53(f) of the Tax Code, payments only to persons enumerated therein are subject to the withholding tax. Considering that interest payments on a loan are not among those specified in said Regulations, said interest payments are not subject to the withholding tax. However, since the aforesaid interest payments are not subject to withholding the borrower corporation shall render an information return on such payments, pursuant to Section 77 of the Tax Code, as amended by Batas Pambansa Blg. 135 and as implemented by Section 21 of Revenue Regulations No. 1-82 dated March 18, 1982. cdta Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue