July 20, 1999
ITAD RULING NO. 006-99
RP-Japan-Art. 11 142-95
Juntec Corporation
Block 5, Lot 7, LIIP-PEZA
Bo. Mamplasan, Biñan, Laguna
Attention: Nilo A. Alinsangan
Managing Director
Gentlemen :
This refers to your letter dated 22 March 1999 requesting a ruling to the effect that the interest income to be remitted by JUNTEC CORPORATION (JUNTEC) to HONKO SEIKOSHO CO., LTD. (HONKO) shall be subject to fifteen per cent (15%) pursuant to the RP-Japan Tax Treaty.
It is represented that HONKO is a non-resident foreign corporation, duly organized and existing under the laws of Japan; that it is not registered either as a corporation/partnership in the Philippines as per certification dated 22 March 1999 issued by the Securities and Exchange Commission; that JUNTEC is a corporation duly organized and existing under the laws of the Philippines; that on 21 March 1997, a Loan Agreement was entered into by and between HONKO and JUNTEC whereby the former made a loan to the latter in the amount of JPY173,067,424.00 or P42,159,225.00 payable within a period of seven (7) years at an interest rate of 5.883% per annum on...
