15% Withholding Tax — Non-Resident Foreign Corporation
BIR Ruling No. 195-81 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Oct 13, 1981
Full text
October 13, 1981 BIR RULING NO. 195-81 24-b-1-iii 080-80 195-81 The HongKong and Shanghai Banking Corporation P.O. Box 1299 Commercial Centre Makati, Metro Manila Attention: Mr . A . R . Servinio Manager-Securities Gentlemen : In reply to your letter dated June 11, 1981, I have the honor to inform you that it having been established that HongKong does not impose any tax on dividends received by corporations domiciled therein from foreign sources, the dividends remitted by you to Atlas Commodities Limited, a non-resident foreign corporation domiciled in HongKong, are subject only to the 15% withholding tax prescribed by Section 24(b)(l)(iii) of the Tax Code, as amended. Very truly yours, ROMULO M. VILLA Acting Commissioner
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