Stepan Philippines Quaternaries, Inc.

June 16, 2020BIR RULING NO. S40-330-20Section 40 (C) (2) & (6) (b), Tax Code of 1997, as amended;BIR Ruling No. 214-12; BIR Ruling No. 075-18Stepan Philippines Quaternaries, Inc.Cocochem Agro-Industrial Park,San Antonio, San PascualBatangasAttention: AAA_______________Gentlemen :This refers to your letters dated November 24, 2016 and February 9, 2018 requesting for a ruling that the proposed corporate restructuring of Stepan Philippines, Inc. ("SPI") and Stepan Philippines Quaternaries, Inc. ("SPQI") in which SPQI acquired substantially all the assets of SPI, qualifies as a tax-free merger under Section 40 (C) (2) in relation to Section 40 (C) (6) (b), both of the National Internal Revenue Code (NIRC) of 1997, as amended. It is represented that SPQI is a corporation duly organized and existing under Philippine laws, with Tax Identification Number ("TIN") 000-000-000-000; that it has an authorized capital stock of ____________________ Pesos (PhP__________) divided into Three Million Three Hundred Sixty Thousand (3,360,000) common shares of stock, with a par value of __________ Pesos (PhP_____) per share; that the amount of capital stock of SPQI which has actually been subscribed...