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June 3, 2019ITAD BIR RULING NO. 010-19Article 13 (Gains from the Alienation of Property) Philippines-Singapore tax treatyNavarro Amper and Co.19th Floor, Net Lima Plaza5th Avenue corner 26th StreetBonifacio Global City1634 Taguig CityAttention: AAA__________BBB__________Gentlemen :This refers to your tax treaty relief application filed on July 17, 2013 requesting confirmation that capital gains derived by NatSteel Asia Pte. Ltd. ("NatSteel") (formerly NatSteel AsiaSteel Pte. Ltd.) from the sale of its shares of stock in SteelAsia Manufacturing Corporation ("SteelAsia") (formerly Tempcore Steel Corporation) to PlaridelSteel, Inc. ("PlaridelSteel") are exempt from income tax pursuant to the Convention between the Republic of the Philippines and the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-Singapore tax treaty"). FACTSNatSteel is a foreign corporation organized and existing under the laws of Singapore and a resident thereof based on its amended Memorandum and Articles of Association and Certificate of Residence issued by the Inland Revenue Authority of Singapore. NatSteel is engaged in the business of iron masters, steel makers, steel...