Philkoie International, Inc.

January 9, 2020ITAD BIR RULING NO. 008-20Section 32 (B) (5), NIRC of 1997, as amended; Section 56 (2),ADB Charter; Article XII, Section 45, Headquarters AgreementPhilkoie International, Inc.Unit 1701, 17th Floor, The Orient Square BuildingF. Ortigas Jr. Road, Ortigas Center, San Antonio1605 Pasig CityAttention: AAA_______________Gentlemen :This refers to your letter dated 29 March 2019 requesting an opinion on whether or not the salaries and emoluments paid by the Asian Development Bank ("ADB") to its _______________, BBB (hereinafter referred to as "BBB") are exempt from income tax. aDSIHcDocuments submitted show that the ADB issued a Certification confirming that BBB is a ___________ for the joint venture of Nippon Koie Co., Ltd. and Professional Research and Consultancy which the ADB has retained as a consultant for TA-9248 MYA: Rural Productivity and Ecosystems Services Enhanced in Central Dry Zone Forest Reserves-TA Implementation Consultant from 12 November 2018 to 31 January 2022; that with reference to the Agreement Establishing the Asian Development Bank ("ADB Charter"), BBB is an expert performing a mission for ADB and as such, is entitled to...