June 7, 2010
BIR RULING [DA-(IL-009) 089-10]
Section 24, RA 7916; DA-(IL-011) 107-08; [DA-(C-165) 432-09]; DA-004-03; DA-412-06
Sycip Gorres Velayo & Co.
6760 Ayala Avenue
1226 Makati City
Attention: F.K. Delos Santos
Tax Services
Gentlemen :
This refers to your letter dated June 24, 2009, on behalf of your client Amkor Technology Philippines, Inc. (ATP), requesting for confirmation of your opinion that realized foreign exchange gains arising from transactions directly attributable to its registered activities are covered by the tax incentives granted by the Philippine Economic Zone Authority (PEZA) to ATP.
It is represented that ATP is a corporation duly organized and existing under and by virtue of the laws of the Philippines; that its principal office address is at Km. 22 East Service Road, South Superhighway, Cupang, Muntinlupa City; that it is registered with the PEZA as an Ecozone Export Enterprise pursuant to its Certificate of Registration No. 00-092; that ATP is primarily engaged in the business of manufacturing, assembling, processing, exporting, buying and selling semiconductor products and components.
It is further represented that in the course of its trade or business, ATP's transactions...
