BIR Ruling No. 182-84

November 23, 1984 BIR RULING NO. 182-84 34 (g)-000-00-182-84 Gentlemen : This refers to your letter dated October 19, 1984 requesting confirmation of your opinion that the contemplated transaction consisting of the repurchase of your own shares which are listed and traded through a local stock exchange shall be subject only to the of 1% tax. It is represented that Filinvest Development Corporation (FDC) is a domestic corporation with an authorized capital stock of P230,000,000 and a paid-up capital of P53,497,430 as of September 30, 1984; that in order to attain operating economies and maximize efficiencies, FDC plans to undertake corporate reorganization through either (a) merger or consolidation with its subsidiary and affiliated companies under Section 35(c)(2) or (b) reduction of its capital stock or (c) combination of both; that FDC plans to effect the reduction of its capital stock by acquiring the purchasing its own shares through the stock exchange; and that the said shares are listed in the stock exchange. In reply, please be informed that your abovementioned opinion is hereby confirmed. Pursuant to Section 34(g) of the Tax Code as amended by Batas Pambansa Blg. 221, a tax of of 1% payable by the seller shall be imposed on the gross selling price of your own shares of stock which, as represented are listed and will be repurchased by you through a local stock exchange. cdta Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner