August 31, 2018
ITAD BIR RULING NO. 080-18
Section 28 (B) (5) (b) National Internal Revenue Code of 1997, as amended Articles 6 (General Rules for Taxation) and 11 (Dividends) Philippines-
United States of America tax treaty
Peopleplus Tech, Inc.
9th Floor, 6780 Building
6780 Ayala Avenue
Makati City
Attention: AAA
_______________
Gentlemen :
This refers to your application filed on July 11, 2016 requesting confirmation that dividends paid by Peopleplus Tech, Inc. ("Peopleplus") to Roen Technology LLC ("Roen") (formerly Joy Technology LLC) are subject to income tax at the rate of 15 percent under Section 28 (B) (5) (b) of the National Internal Revenue Code of 1997, as amended ("Tax Code").
FACTS
Roen is a foreign corporation organized and existing under the laws of the United States. It is not a registered corporation or partnership in the Philippines. As of March 31, 2016, Roen is the registered owner of 29,750 common shares of stock of Peopleplus with par value of P_____ each or a total of P__________, which represent 99 percent ownership in Peopleplus. On June 10, 2016, the Board of Directors of Peopleplus approved a resolution...
