16 CIR v. Procter and Gamble (1988)
16 CIR v. Procter and Gamble (1988)
16 CIR v. Procter and Gamble (1988)
Petitioner/s:
Respondent/s:
Facts:
● Procter and Gamble Philippine Manufacturing Corporation (PMOPhil) is engaged
in business in the Philippines and is a wholly owned subsidiary of Procter and
Gamble, U.S.A. (PMC-USA), a non-resident foreign corporation in the Philippines,
not engaged in trade and business therein
● PMC-U.S.A. is the sole shareholder of PMC-PhiL and is entitled to receive income
from PMC-Phil. in the form of dividends. PMC-Phil. also has a legal personality
separate and distinct from PMC-U.S.A.
●
○ a
Ruling:
W/N – YES/NO
●
○
Dispositive
WHEREFORE,