Bureau of Internal Revenue

BIR Rulings

BIR Ruling [SB-(004) 033-10]

June 1, 2010

BIR 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-69-98

NEC Technologies Hongkong Limited
Manila Regional Office
27th Floor Petron Mega Plaza
358 Sen. Gil J. Puyat Avenue,
Makati City, Philippines

Attention: Mr. Hiroshi Kohriyama
General Manager/
Chief Regional Officer

Gentlemen :

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. aAcHCT

It 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...

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

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