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October 22, 2018ITAD BIR RULING NO. 093-18Section 28 (B) (5) (b) National Internal Revenue Code of 1997,as amendedAngara Abello Concepcion Regala and Cruz Law Offices22nd Floor, ACCRALAW Tower2nd Avenue corner 30th StreetCrescent Park WestBonifacio Global City0399 Taguig CityAttention: AAABBBCCCGentlemen :This refers to your letters dated May 4, 10 and 17, 2016 requesting confirmation that dividends paid by Metro Pacific Investments Corporation ("MPIC"), Security Bank Corporation ("Security Bank") and DMCI Holdings, Inc. ("DMCI") to Cartica Investors L.P. ("Cartica Investors") and Cartica Capital Partners Master L.P. ("Cartica Capital") are subject to income tax at the rate of 15% under Section 28 (B) (5) (b) of the National Internal Revenue Code of 1997, as amended ("Tax Code"). aDTSHcFACTSCartica Investors is foreign partnership organized and existing under the laws of the Cayman Islands based on its Amended and Restated Agreement of Limited Partnership and the Partnership Certificate of Existence issued by the Registrar of Limited Partnerships of the Cayman Islands. The purpose of Cartica Investors is to acquire, own and dispose securities and engage in financial transactions relating thereto...