BIR Ruling No. 34-2020

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE

BUREAU OF INTERNAL REVENUE

Quezon City

JAN 2 4 2020 0T-034-2020

SUMISHO MOTOR FINANCE CORPORATION 12th Flr. PSBank Center, Paseo de Roxas cor. Sedefio St.. Makati City 1226

Attention:HAZEL GRACE A.ABELLA Comptroller

Gentlemen:

tax rate applicable for interest payments to Sumisho Motor Finance Corporation's bank creditors related to its loans payable evidenced by promissory notes which are not securitized, This refers to your letter dated November 12, 2018 requesting for clarification on the

assigned, or participated.

District Office No. 050 dated October 11,2018, re: Notification to Withholding Agents As represented, Sumisho Motor Finance Corporation received a letter from Revenue

Required to Deduct Creditable Withholding Taxes for Purchases of Goods and Services.

sufficiently addressed by Section 2 (D of Revenue Regulations (RR) No.11-2018,Amending Certain Provisions of Revenue Regulations No. 2-98, as Amended, to Implement Further In reply, please be informed that the subject matter of your request has already been

Amendments Introduced by Republic Act No.10963,Otherwise Known as the"Tax Reform for

Acceleration and Inclusion (TRAIN)"Law, Relative to Withholding of Income Tax," dated

January 31, 2018, in relation to Revenue Memorandum Circular (RMC No. 84-2012.

"Clarifying Tax Treatment of Interest Income Earnings on Loans That are Not Securitized, Assigned or Participated Out,"dated December 21, 2012. Hence, a clarificatory ruling or opinion is unnecessary. In this regard, ycu are advised to strictly comply with the provisions of the said RR and RMC.

Very truly yours.

ieovy

CAESARR.DULAY

Commissioner of Internal Revenue

K-1-LMAT 032360