BIR Ruling [UN-146-94]
BIR Ruling [UN-146-94] • Bureau of Internal Revenue (BIR) Issuances • Rulings (Unnumbered) • Apr 26, 1994
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April 26, 1994 BIR RULING [UN-146-94] Sakamoto Orient Chemical Corporation Unit 5D Plaza Royale 120 Alfaro St., Salcedo Village Makati, Metro Manila Attention: Mr . Cesar F . Cabanos Accounting Manager Gentlemen : This refers to your letter dated January 6, 1994, in effect, requesting authorization from this Office for you to apply your tax credit certificates against your withholding tax liability as the withholding agent of the final income tax due on interest income paid to a foreign creditor. In reply, I regret to inform you that your request cannot be granted. Tax credit certificates, even if issued by the Board of Investments (BOI), cannot be used by the grantee to pay the income and withholding tax liabilities of the foreign creditor. (VAT Ruling No. 123-90 dated May 14, 1990) cdtech Very truly yours, JAIME M. MAZA Assistant Commissioner (Legal Service)
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