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June 22, 1999ITAD RULING NO. 010-99RP-Netherlands Article 11Mr. Ayasamy RamajilluFinancial Controller and Vice PresidentPhilips Semiconductors Phils., Inc.Cabuyao, LagunaPHILIPPINESS i r :This pertains to your letters dated 26 January 1999 and 26 March 1999 requesting for three (3) year extension of the approval issued to you by this Office dated 10 June 1998 granting the 15 percent preferential tax rate on interest payments by your Company to Koninklije Philips Electronics N.V. of the Kingdom of the Netherlands in accordance with the Philippines-Netherlands Tax Treaty.Documents disclosed that Koninklije Philips Electronics N.V. (KPEN) is a non-resident foreign corporation organized and existing under the laws of the Netherlands with principal address at Groenewoudsewg 1, 5621 BA Eindhoven, Netherlands; that it has no permanent establishment in the Philippines as evidenced by its Certificate of Non-Registration from the Securities and Exchange Commission dated 24 February 1999; that it renewed its Term Loan Agreement dated 3 January 1999 with its subsidiary, Philips Semiconductors Phils., Inc. (PSPI), a domestic corporation organized and existing under the laws of the Philippines with principal address at...