BIR Ruling No. 200-82

June 21, 1982 BIR RULING NO. 200-82 053-e 000-00 200-82 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 February 23, 1981 in behalf of the NATIONAL GRAINS AUTHORITY requesting exemption from the withholding tax provision of Section 53(e) of the Tax Code, as amended by Presidential Decree No. 1739 and implemented by Revenue Regulations No. 12-80. In reply, please be informed that since the National Grains Authority is exempt from payment of income taxes pursuant to Section 6(d)(ii) of Presidential Decree No. 4, as amended by Presidential Decree No. 1485, dated June 11, 1978, its interest income on bank deposits 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 substitutes prescribed by Section 24(cc) in relation to Section 53(e) both of the Tax Code, as amended. The National Grains Authority is not covered by Presidential Decree No. 1177, which requires all units of government, including government-owned or controlled corporations to pay income taxes effective July 30, 1977, since Presidential Decree No. 1485 is a later law. This serves as authority of the depository banks to forego withholding of the tax on the interest earnings of the deposits maintained by the National Grains Authority with them. Very truly yours, RUBEN B. ANCHETA Acting Commissioner