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

Key points

1. PCD Nominee-Filipino. Unless it is satisfactorily shown that the actual equity investor is a domestic corporation, the recipient is deemed an individual. The dividends are subject to 10% Final Withholding Tax under Section 24(B)(2) of the Tax Code.
2. PCD Nominee-Non Filipino. Unless the actual equity investor is shown to be a resident alien, a non-resident alien (engaged or not engaged in trade or business in the Philippines) or a resident foreign corporation, the recipient is deemed a non-resident foreign corporation. The dividends are subject to 30% Final Withholding Tax under Section 28(B)(1) of the Tax Code.

Who is affected

• PCD Nominee-Filipino
• PCD Nominee-Non Filipino