Applicable Withholding Tax Rates on Interest Payments of Peso-Denominated Comm'l Papers of San Miguel Corp.

November 19, 1993 BIR RULING NO. 451-93 APPLICABLE WITHHOLDING TAX RATES ON INTEREST PAYMENTS OF PESO-DENOMINATED COMM'L PAPERS OF SAN MIGUEL CORP. 24 00-00 51-93 San Miguel Corporation 40 San Miguel Avenue Mandaluyong, Metro Manila Attention: Mr . Alberto M . de Larrazabal Vice-President This refers to your letter dated July 27, 1993, stating that San Miguel Corporation (SMC), a domestic corporation engaged in the manufacture of beer and food products, contemplates to issue in August 1993 peso-denominated long-term commercial papers (LTCPs) to nationals of countries with whom the Philippines has tax treaties such as USA, Japan, United Kingdom of Great Britain and Germany. cdtech In connection therewith, you are requesting for confirmation of your opinion to the effect that the applicable withholding tax rates on interest payments to non-resident purchasers of the LTCPs are those prescribed in the corresponding tax treaties which the Philippines has with the foreign countries. In reply thereto, please be informed that your opinion is hereby confirmed. The applicable withholding tax rates on interest payments to non-resident purchasers of the LTCPs are those prescribed in the tax treaties which the Philippines has entered into with aforementioned foreign countries. LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue