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June 1, 2010BIR RULING [SB-(004) 033-10]Sec. 32 (B) (6) (b); BIR Ruling No. 163-92; DA-350-97; DA-427-99; DA-222-2007; SB-69-98NEC Technologies Hongkong LimitedManila Regional Office27th Floor Petron Mega Plaza358 Sen. Gil J. Puyat Avenue,Makati City, PhilippinesAttention: Mr. Hiroshi KohriyamaGeneral Manager/Chief Regional OfficerGentlemen :This refers to your letter dated August 19, 2008 requesting tax exemption of the separation benefits to be received by the employees of NEC Technologies Hongkong Limited ("NTH-MRO" for brevity) due to its closure under Section 32 (B) (6) (b) of the Tax Code of 1997. aAcHCTIt is represented that NTH-MRO, with Taxpayer Identification No. 000-655-370, is a corporation engaged in production management which has suffered continuous operational/financial reverses for the past years; that despite sincere efforts to maintain the operations, the country's depressed economic situation and the continuing decline in the demand of FDD in the international market collectively contribute to continuous financial reverses further diminishing the corporation's competitiveness; that in view of said developments, the Board of Directors of NEC Technologies Hongkong, Ltd. has found no other recourse but to cease business operations...