BIR Ruling [UN-380-A-95]

October 23, 1995 BIR RULING [UN-380-A-95] Sycip Gorres Velayo & Co. 6760 Ayala Avenue Makati, Metro Manila Attention: Atty . J . A . Osana Tax Division Gentlemen : In connection with the internal revenue tax case of your client, The Hongkong & Shanghai Banking Corporation, involving the amounts of P840,842.71, P11,610,366.46, P50,580,676.84 and P42,705,777.90 representing deficiency withholding taxes on interest expense on deposits and deficiency gross onshore taxes, respectively, inclusive of surcharge, interest and compromise penalty for the years 1988 and 1989, please be informed that after a careful study of the facts of the case and the law applicable thereto, this Office has finally arrived at the conclusion that your client is not liable to pay the aforesaid amounts. You may, therefore, consider the case closed and terminated. Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue