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November 19, 2018ITAD BIR RULING NO. 118-18Article 10 (Dividends), Philippines-Singapore tax treatyNavarro Amper and Co.19th Floor, Net Lima Plaza5th Avenue corner 26th StreetBonifacio Global City1634 Taguig CityAttention: AAA_______________Gentlemen :This refers to your tax treaty relief application filed on December 21, 2012 requesting confirmation that cumulative dividends paid by SteelAsia Manufacturing Corporation ("SteelAsia") (formerly Tempcore Steel Corporation) to NatSteel Asia Pte. Ltd. ("NatSteel") (formerly NatSteel AsiaSteel Pte. Ltd.) upon the redemption of SteelAsia's preferred shares are subject to income tax at the rate of 15% 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, the Business Profile issued by the Registrar of Companies and Businesses of Singapore, and Certificate of Residence issued by the Inland Revenue Authority of Singapore. NatSteel is engaged in...