Re: Foreign Equity Ownership; Travel and Tours

March 19, 2018

SEC-OGC OPINION NO. 04-18

RE: FOREIGN EQUITY OWNERSHIP; TRAVEL AND TOURS

AT Phil., Inc.
G/F, Integrated Bar of the Philippines Building
Corner Edgardo Angara Wing, Jade St.
Ortigas Center, Pasig City

Attention: Vivian San Mateo
Loida G. Samaniego

Mesdames :

This refers to your letter dated 21 June 2017, requesting an opinion on whether or not AT Phil., Inc. (API), doing business under the name and style of ASIATRAVEL.COM, as amended on November 16, 2009, is qualified to have foreign equity of 100%.

You mentioned in your letter that API has been operating since its inception, pursuing its business of tours and travel agency and other related activities, servicing both local and foreign markets. It has not engaged in any of its secondary purposes except those related to travel and tours. You further stated that since its incorporation and up to 21 June 2017, its stockholdings are divided between Filipino and Singaporean investors at a share of 60% and 40%, respectively. The company's total authorized capital stock is fifteen million pesos (Php15,000,000.00) divided into the same number of shares of fifteen million (15,000,000)...

AIC Grande Tower Garnet Road
Ortigas Center, Pasig City
Metro Manila Philippines

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