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November 19, 2018ITAD BIR RULING NO. 117-18Section 28 (B) (5) (b), National Internal Revenue Code of 1997,as amendedIsla Lipana and Co.29th Floor, Philamlife Tower8767 Paseo de Roxas1226 Makati CityAttention: AAA_______________Gentlemen :This refers to your letter dated August 15, 2017 requesting confirmation that dividends paid by Century Pacific Food, Inc. ("Century Pacific") to Albizia ASEAN Opportunities Fund ("Albizia") are subject to income tax of 15% under Section 28 (B) (5) (b) of the National Internal Revenue Code of 1997, as amended ("Tax Code"). FACTSAlbizia is a corporation organized and existing under the laws of the Cayman Islands based on its Amended and Restated Memorandum of Association and Certificate of Incorporation issued by the Registrar of Companies of the Cayman Islands. The objects for which Albizia is established are unrestricted. Based on a certification issued by the Governor in Cabinet of the Cayman Islands, and pursuant to Section 6 of the Tax Concessions Law of 1999 of the Cayman Islands, no law enacted in the Cayman Islands imposing any tax on profits, income, gains, or appreciations shall...