n\a

October 23, 2018ITAD BIR RULING NO. 107-18Articles 5 (Permanent Establishment) and 8 (Business Profits) Philippines-United States of America tax treatyPunongbayan and Araullo19th and 20th Floors, Tower 1The Enterprise Center6766 Ayala Avenue1200 Makati CityAttention: AAA_______________Gentlemen :This refers to your tax treaty relief application filed on November 14, 2011 requesting confirmation that service fees paid by Chevron Geothermal Philippines Holdings, Inc. ("Chevron Philippines") (now known as Chevron Geothermal Philippines Holdings LLC) to Thermochem, Inc. ("Thermochem") are exempt from income tax pursuant to the Convention between the Government of the Republic of the Philippines and the Government of the United States of America with Respect to Taxes on Income ("Philippines-United States tax treaty"). HTcADCFACTSThermochem is a corporation organized and existing under the laws of the United States and a resident thereof based on its Articles of Incorporation and Certificate of Residence issued by the Internal Revenue Service. Thermochem is engaged in providing chemical engineering, laboratory analysis, geochemistry and field testing services and products to a wide range of energy industries. The primary focus of Thermochem is to protect...