Remittance of $15,000.00 to the Tecumseh Products Company of Michigan, U.S.A.
BIR Ruling No. 347-60 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Aug 16, 1960
Full text
August 16, 1960 BIR RULING NO. 347-60 The Ysmael Mfg. Co. 222 Espaa Extension Quezon City Gentlemen : This is in answer to your letter dated August 12, 1960 wherein you inquired whether your remittance of $15,000.00 to the Tecumseh Products Company of Michigan, U.S.A. is subject to withholding tax. Compensation for services performed outside the Philippines is not subject to income. (Sec. 37(c)(3), Tax Code). Accordingly, since Tecumseh Products Company is a non-resident entity not engaged in business in this country and if it is true, as you alleged, that your remittance of $15,000.00 to said company is in payment of services rendered by it in the training of your personnel in the United States, the said remittance is not subject to income tax and, therefore, not subject to the withholding tax. Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue
Ask what this means for your situation
The assistant quotes the passage it relies on and links the source, so you can check every figure it gives you.