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July 20, 1999ITAD RULING NO. 008-99RP-Japan Art. 10Juntec CorporationBlock 5, Lot 7, LIIP-PEZABo. Mamplasan, Biñan,Laguna, PhilippinesAttention: Nilo A. AlinsanganManaging DirectorGentlemen :This refers to your application for relief from double taxation dated 22 March 1999 on behalf of HONKO SEIKOSHO CO., LTD., requesting for a preferential tax rate of ten per cent (10%) to be withheld on dividend remittances by JUNTEC CORPORATION pursuant to the RP-Japan Tax Treaty.It is represented that HONKO SEIKOSHO CO., LTD. is a non-resident foreign corporation duly organized and existing under the laws of Japan, with no permanent establishment here, while JUNTEC CORPORATION is a domestic corporation organized and existing under the laws of the Philippines; that HONKO SEIKOSHO CO., LTD. holds ninety nine and 99/100 per cent (99.99%) of the capital stock of JUNTEC CORPORATION; that on 19 December 1998, the Board of Directors of the latter passed and approved the declaration of cash dividend in the amount of P3,000,000.00 from its unrestricted retained earnings, payable to the stockholders of record as of 31 July 1998. cdtaiBased on the foregoing, you...