BIR Ruling No. 183-11
BIR Ruling No. 183-11 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jun 7, 2011
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June 7, 2011 BIR RULING NO. 183-11 Manabat Delgado Amper & Co. 5th F, Salamin Building, 197 Salcedo Street Legaspi Village, Makati City Attention: Myra V. Torres Tax Manager Gentlemen : This refers to your letter dated September 13, 2010 requesting for a confirmation of your opinion that the rental income derived by a Nonresident Foreign Corporation from Hitachi Global Storage Technologies Philippines Corporation, a domestic corporation, are subject to the 7.5% withholding tax as provided under Section 28 (B) (4) of the National Internal Revenue Code as amended. This Office declines to issue a ruling on the matter as the request does not involve genuine points of doubt or difficulty to taxpayers or their professional advisers. Very truly yours, (SGD.) KIM S. JACINTO-HENARES Commissioner of Internal Revenue
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