RMC No. 73-2014 — Clarifies the Withholding Tax rates on dividend payments to Philippine Central Depository Nominees

REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE iehtippines BUREAU OF INTERNAL REVENUE

Quezon City

September 12, 2014

revenue memorandum circular no. 33- 2014

SUBJECT Clarification of Withholding Tax Rates on Dividend Payments to Philippine Central Depository (PCD) Nominees

TO All Internal Revenue Officers and Others Concerned

withholding tax rates pertaining to dividend payments to PCD Nominees by the issuers of securities. For the information and guidance of all concerned, this Circular clarifies the appropriate

to withhold appropriate taxes based on Sections 24(B)(2), 25(A) (2), 25(B), 27(D)(4) 28(A)(7)(d), and 28(B)(1) of the Tax Code in relation to Section 57 of the same Code. On the payment of dividends to PCD Nominees, a declaring corporation (issuer) is required

to final withholding tax of ten percent (10%) under Section 24(B)(2) of the Tax Code. investor is a domestic corporation, the income recipient is deemed to be an individual subject In case of PCD Nominee- Filipino, unless it is satisfactorily shown that the actual equity

actual eguity investor is resident alien, non-resident alien whether engaged or not engaged in trade or business in the Philippines or resident foreign corporation, the income recipient is deemed to be a nonresident foreign corporation subject to final withholding tax of thirty percent (30%) under Section 28(B)(1) of the Tax Code. Further, in case of PCD Nominee- Non Filipino, unless it is satisfactorily shown that the

All other issuances inconsistent herewith are hereby repealed or modified accordingly

a publicity as possible. All concerned are hereby enjoined to be guided accordingly and give this Circular as wide

This Circular shall take effect immediately.

BUREAU OF INTERNAL REVENUE RECORDS MGT. DIVISION SEP : 5 2014 8:45A.M. Commissioner/of Internal Revenue KIM S.JACINTO-HENARES 026764

AM RECEIVEDG IE INTERNAL REVENU

COMMUNICATIONS DIVISION

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