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June 25, 2010BIR RULING [DA-(ECB-001) 110-10]Sec. 33 (A); BIR Ruling 013-02; DA 350-04; DA 023-06; DA-323-07; DA-013-08Carag de Mesa & Zaballero Law OfficesSuite 2602, 26th Floor, The Atlanta CentreNo. 31 Annapolis Street, 1500 Greenhills,San Juan CityAttention: Attys. Priscilla F. ZaballeroMaria Theresa C. San PabloGentlemen :This refers to your letter dated January 19, 2010 requesting confirmation of your opinion that the allowances given by your client, Top Express Infrastructure Limited ("Top Express"), to its Technical Support Specialists, Project Managers and Senior Managers are non-taxable fringe benefits and hence, not subject to fringe benefits tax or income tax and consequently, withholding tax on compensation. It is represented that Top Express, with TIN 270-818-498-000, is a company created under the laws of the Hong Kong Special Administrative Region and licensed to do business in the Philippines. It is engaged in the business of installation and commissioning of telecommunications equipment and network as well as providing other technical assistance, support, training and testing, advisory, research and development services related to telecommunications.Top Express maintains a sizeable number of employees whose...