Interests Paid by BPI on Account of Promissory Notes

July 7, 1959 BIR RULING NO. 332-59 Messrs. Aviado & Aranda Attorneys-at-Law P.O. Box No. 777 M a n i l a Gentlemen : In answer to your letter dated May 29, 1959, I have the honor to inform you that, as B.I.R. Ruling No. 629 dated October 3, 1958 is later than the ruling dated July 26, 1956, the former necessary repeals the latter. Such being the case, interests being paid by your client, the Bank of the Philippine Islands, on account of promissory notes executed and payable by it to the order of the Export-Import Bank of Washington, representing financial accommodations granted by the latter to the former, are now subject to the withholding provisions of Section 54, in relation to Section 53 of the Tax Code. cdta Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue