Domestic Taxpayers who have direct equity participation of at least 50% (fifty percent) of the total paid-up shares in a Non-Listed Foreign Company; or jointly with other domestic Taxpayers have direct equity participation of at least 50% of the total paid-up shares in a Non-Listed Foreign Company, are deemed to have direct control over the Non-Listed Foreign Company.
The amount of deemed dividend is the percentage of ownership multiplied by the income of the CFC.
The income used to compute deemed dividends is derived from certain passive income. The deemed dividend is due at the end of the fourth month after the tax returns reporting period ends.