BIR Ruling No. 228-82

July 30, 1982 BIR RULING NO. 228-82 24-B-iii 118-81 228-82 Fuller Paint Mfg. Co. (Phil.), Inc. Warner Barnes Building 2900 Faraday St., South Expressway Makati, Metro Manila Attention: Ms . Violeta D . Echevarria Accounting Manager Gentlemen : This refers to your letter dated March 22, 1982 requesting a certification from this Office that the dividends which you will remit to your American shareholder, Fuller O'Brien Corporation of San Francisco, California, USA, is subject to withholding tax at the rate of 15%. It is represented that the recipient corporation is a non- resident foreign corporation not engaged in trade or business in the Philippines, owning 40% of Fuller Paint Manufacturing Co. (Phil.), Inc. In view thereof, and considering that under the present provisions of the U.S. Federal Tax Code, the amount the tax deemed paid on such dividends, and accordingly, to be credited against U.S. tax on said dividends meets the 20% requirement of Presidential Decree No. 369, this Office hereby certifies that the cash dividends which you will remit to Fuller O'Brien Corporation domiciled in the United States are subject to withholding tax at the rate of 15% only, pursuant to Section 24(b)(iii) of the Tax Code, as amended. aisadc Very truly yours, RUBEN B. ANCHETA Acting Commissioner