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June 3, 2019ITAD BIR RULING NO. 011-19Section 28 (B) (5) (b) National Internal Revenue Code of 1997, as amendedSycip Gorres Velayo and Co.6760 Ayala Avenue1226 Makati CityAttention: AAA__________Gentlemen :This refers to your letter dated February 29, 2016 requesting confirmation that dividends paid by Hyundai Asia Resources, Inc. ("HARI") to Kibo Holdings Ltd. ("Kibo Holdings") of the British Virgin Islands are subject to income tax at the rate of 15% under Section 28 (B) (5) (b) of the National Internal Revenue Code of 1997 ("Tax Code"), as amended.FACTSKibo Holdings is foreign corporation organized and existing under the laws of the British Virgin Islands ("BVI") based on its Articles of Association and Certificate of Incorporation. Based on the Certificate of Tax Exemption issued by the Inland Revenue Department of BVI on December 24, 2015, Kibo Holdings was incorporated as an International Business Company in BVI on April 25, 2008. Pursuant to Section 242 (1) and (3) of the BVI Companies Act of 2004, Kibo Holdings is exempt from all provisions of the Income Tax Ordinance and is...