BIR Ruling No. 240-83
BIR Ruling No. 240-83 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Dec 29, 1983
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December 29, 1983 BIR RULING NO. 240-83 This refers to your letter dated October 21, 1983 requesting confirmation from this Office that Zephyr Investment Co. Ltd., a United Kingdom based corporation is entitled to the reduced 25% withholding tax on all cash dividends derived from Philippine corporation instead of the regular 35% withholding tax. It is represented that your client, Zephyr Investment Co., Ltd. is a United Kingdom-based corporation and is registered in London under Registration Number 1188573; that it received P18,000 cash dividends from AGP Industrial Corporation, a Philippine corporation from September 4, 1981 to September 9, 1983 for its clients, the beneficial owners of such dividends who are all residents of United Kingdom. In reply, please be informed that Article 9 paragraph (b) of the RP-UK Tax Treaty provides that dividends derived from a company which is a resident of the Philippines by a resident of the United Kingdom who is the beneficial owner thereof, may be taxed in the Philippines at 25% of the gross amount of the dividends. In view thereof, the P18,000 cash dividends received by Zephyr Investment Co., Ltd. from AGP Industrial Corporation from September 4, 1981 to September 9, 1983 are subject to 25% withholding tax. aisadc Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue
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