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March 2010

Tax brief

Contents 02 New Laws Expanded Senior Citizens Act of 2010 Reduction of taxes on life insurance policies 03 Court Decisions Court Refund of excess creditable VAT withheld VAT on cinema ticket sales Tax on offline international carriers 04 BSP Circular Guidelines for establishing cooperative banks 06 BIR Issuances Amendments to the OSD regulations Submission of statement of management responsibility 2010 BIR strategy map Joint IRR implementing RA 9520, otherwise known as Philippine Cooperative Code of 2008 BIR RIP Project Guidelines for monitoring big-ticket items Minimum gross sales of motels for VAT purposes 09 BIR Rulings Rulings Cellular phone allowance Long-term UITF exempt from 20% FWT Ascertaining worthlessness of bad debts 10 Highlight on P&A services services CTA litigation support

March 2010

New Laws
Expanded Senior Citizens Act of 2010 The law grants additional benefits and privileges to senior citizens, including exemption from valued added tax (VAT) on their purchases of goods and services, which are entitled to the 20% discount. Other incentives and benefits include, among others, the following: 1. Free vaccination against influenza and pneumococcal disease for indigent senior citizens Benefit assistance in the amount of P2,000 to the nearest kin of a deceased indigent senior citizen Grant of 5% discount on water and electric bills registered in the name of the senior citizen, provided that consumption is below 100 kilowatt-hours of electricity and 30 cubic meters of water a month Additional government assistance, i.e., social pension/ monthly stipend of P500, mandatory PhilHealth coverage, and social safety assistance (food, medicines and financial assistance) Death benefit assistance in the amount of P2,000 in case of death of an indigent senior citizen, which shall be awarded to his or her nearest kin In the purchase of goods and services that are on promotional discount, the law provides that senior citizens have the option to avail of either the promotional discount or the 20% discount, whichever is higher. With regard to the 20% discount on purchase of medicines, the law mandates the Department of Health (DOH) to establish a mechanism of compulsory rebates in the sharing of burden of discount among retailers, manufacturers and distributors. On the other hand, the provision of Republic Act (RA) 7432, which grants benefactors of senior citizens the privilege to claim the senior citizen as a dependent for tax purposes, has been deleted. To ensure compliance with the law, stiffer penalties are imposed against sellers of goods and services who refuse to extend the benefits granted to senior citizens. First-time violators of the law shall be subject to a fine of P100,000 and imprisonment of at least two years to not more than six years. On the other hand, any senior citizen who abuses the privilege granted under the law also faces a fine of P50,000 to P100,000 and imprisonment of not less than six months. (Republic Act No. 9994, February 15, 2010) Reduction of taxes on life insurance policies With regard to life insurance policies, the law has lowered the premium tax from 5% to 2%, and revised the documentary stamp tax (DST). The reduced premium tax shall apply to all life insurance policies sold after the effectivity of the new law, and to the remaining balance for the remaining years of the life insurance policies that were issued before the law took effect but whose premiums have not yet been fully paid. The new law also replaces the 0.25% DST on premiums collected from life insurance policies to the graduated DST rates, which range from P10 to P100 based on the value of the insurance policy. However, the provision of the law that eliminates the premium tax and DST on life insurance policies after five years from its effectivity was vetoed by the President. (Republic Act No. 10001, February 23, 2010)

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March 2010

Court Decisions
VA Refund of excess creditable VAT withheld Although the law does not expressly state that excess creditable VAT withheld is refundable, it may be the subject of a claim for refund as an erroneously collected tax under Sections 204(C) and 229 of the Tax Code. In the instant case, the excess creditable VAT withheld consists of amounts withheld and remitted to the Bureau of Internal Revenue (BIR) by government agencies that applied the 6% withholding rate on their payments to the taxpayer-refund claimant. Since the taxpayer had no more output VAT against which the excess creditable VAT withheld may be applied or credited, the taxpayer claimed for refund of its excess creditable VAT withheld. The Supreme Court (SC) held that creditable VAT withheld should be treated as advance payment for the taxpayerrefund claimants VAT liability payable and, therefore, the difference should be treated as the taxpayers overpaid taxes. Citing Citibank N.A. v. Court of Appeals, which dealt with excessive income taxes withheld but considered applicable by the SC, the Court held that tax withheld, while collected legally, became untenable and took on the nature of erroneously collected taxes. It was, however, clarified by the SC that its ruling only refers to the creditable VAT withheld imposed previously under Section 114 of the Tax Code. After the amendment by RA 9337, the amount withheld under Section 114 will now be treated as a final VAT and will thus no longer be under the creditable withholding tax system. (Commissioner of Internal Revenue v. Ironcon Builders and Development Corporation, GR 180042, February 8, 2010) Tax on offline international carriers An offline international carrier selling passage documents through an independent sales agent in the Philippines is considered engaged in trade or business in the Philippines subject to the 32% (now 30%) tax imposed under Section 28(A)(1) of the NIRC of 1997. The SC held that although an offline carrier, which does not maintain flights to or from the Philippines, is not taxable to the 2 % tax having no gross Philippine billings (GPB) as defined under Sec. 28(A)(3)(a) of the 1997 NIRC it is not exempt from paying any income tax for its sale of passage documents in the Philippines. As the SC ruled, such offline international carrier should be considered a resident foreign corporation subject to the 32% (now 30%) tax under Sec. 28(A)(3) of the Tax Code. The rule promulgated by the SC is that, if the 2 % tax on GPB under Sec. 28(A)(3)(a) is applicable to a taxpayer, then the general rule imposing 32% tax under Sec. 28(A)(1) of the Tax Code would not apply. If, however, Sec. 28(A)(3)(a) does not apply, a resident foreign corporation whether an international air carrier or not shall be liable to the 32% tax under Sec. 28(A)(1) of the Tax Code. This means that an international air carrier that maintains flights to and from the Philippines shall be taxed at the rate of 2 1/2% of its GPB, while an international air carrier that does not have flights to and from the Philippines, although exempt from 2 % tax on GPB, is subject to 32% (now 30%) tax on its income earned from other activities in the country. (South African Airways v. Commissioner of Internal Revenue, February 16, 2010, GR 180356) ticket VAT on cinema ticket sales The activity of showing cinematographic films is not a service covered by VAT under the National Internal Revenue Code (NIRC) of 1997, as amended, since it is not included in the enumeration of sale or exchange of services. The activity does not fall under the phrase similar services either, which would have subjected it to the VAT. The SC held that the activity is instead subject only to the amusement tax under RA 7160, otherwise known as the Local Government Code (LGC) of 1991. According to the SC, although it was the national government that imposed the amusement taxes on operators and proprietors of theaters under the NIRC of 1939, this power to impose tax on amusement has been transferred to, and remains exclusively with, the local government units (LGUs). The SC pointed out that the legislature never intended to impose VAT on operators or proprietors of cinema/theater houses, which are already covered by the amusement tax under the LGC. It also stressed that levying the 10% VAT, in addition to the 30% amusement tax imposed by Section 140 of the LGC, would impose an unreasonable burden on operators or proprietors of cinema/theater houses, resulting in injustice since persons taxed under the NIRC of 1997 would be in a better position than those taxed under the LGC of 1991. Hence, in the absence of any provision of law imposing VAT on the gross receipts of cinema/theater operators or proprietors derived from admission tickets, the SC upheld the cancellation of the deficiency VAT assessment issued against the taxpayer. (Commissioner of Internal Revenue v. SM Prime Holdings Inc., and First Asia Realty Development Corporation, GR 183505, February 26, 2010)

March 2010

BSP Circular
Guidelines for establishing cooperative banks The BSP has issued the revised rules and regulations governing the organization, establishment, supervision and regulation of cooperative banks pursuant to the provisions of RA 9520 or the Philippine Cooperative Code of 2008. The guidelines for establishing cooperative banks are as follows: A. Registration, application procedures and pre-operating requirements To establish a cooperative bank, cooperatives forming the bank should have a minimum paid in capital of P10 million. No cooperative member shall own or control more than 40% of total contributions of a cooperative bank. A prospective cooperative bank shall file its application for licensing as a bank with the Bangko Sentral ng Pilipinas (BSP), and upon approval, shall be registered with the Cooperative Development Authority (CDA). Duly registered cooperatives applying for authority to establish a cooperative bank shall be required to submit documents as well as comply with the pre-operating requirements specified under the Manual of Regulation for Banks. B. Guidelines on establishment of cooperative banks and branches Five cooperatives are needed to establish a cooperative bank. The majority of the banks voting shares should be held by its member-cooperatives, which are located in the province where the head office is located. Only one cooperative bank may be established in each province. The establishment of an additional cooperative bank may be allowed in the same province provided it is located in a city or municipality other than the one where the first cooperative is situated. A cooperative bank may set up branches/ extension offices or other banking offices anywhere within the province where it is located, or in cities or municipalities where there are no other cooperative bank head offices, branch/extension offices, or other banking offices. The establishment of branches shall be subject to the prescribed minimum combined capital requirement, ranging from P10 million to P100 million, depending on the location of the head office and its branches. C. Authorized undertakings A cooperative shall provide financial, banking and credit services to cooperatives and their members, although it may also provide similar services to non-members or to the general public. A cooperative bank with existing investment in insurance companies and insurance cooperatives may reduce, and once reduced, may not increase its equity holdings. The entire equity holdings of a cooperative bank in an insurance company must be divested within five years from the effectivity of the circular. D. Privileges, incentives and assistance to cooperative banks Cooperative banks shall be given the same privileges and incentives granted to rural banks, thrift banks, commercial banks, and universal banks to rediscount notes with the BSP, the Land Bank of the Philippines, and other government banks. It shall also be exempt from publication requirement on foreclosure of mortgages and execution of judgment involving real properties levied upon by a sheriff. Instead, notices of foreclosures and execution of judgment should be posted in conspicuous areas in the banks premises and other areas for a period of 60 days. (BSP Circular No. 682, February 15, 2010)

March 2010

BIR Issuances
Amendments to the OSD regulations The BIR has amended Revenue Regulations No. (RR) 16-08 the Optional Standard Deduction (OSD) regulations relative to the manner of claiming the OSD, which is allowed of general professional partnerships (GPP) and their partners, and to the procedure for disclosing the election to use OSD in the taxpayers income tax returns. Under the new regulations, the type of deduction used by the GPP must be the same type of deduction availed of by the partners. Previously, under RR 16-08, the GPP and each of the partners were allowed to choose their own method of deductions. Specific rules that should be followed by the GPP and partners in electing deductions are as follows: 1. If the GPP chooses itemized deductions, the partners comprising it must also claim itemized deductions, which are in the nature of ordinary and necessary expenses for the practice of profession that were not claimed by the GPP during the year. If the GPP avails of the OSD in computing its net income, the partners can no longer claim further deductions from their share in the net income of the GPP. 3. If the partner derives other gross income from trade, business or practice of profession apart and distinct from his share in the net income of the GPP, the deduction that he can claim from his other gross income would follow the same deduction availed of from his partnership income, provided that if the GPP opts for the OSD, the individual partner may still claim 40% of his gross income but not include his share from the net income of the GPP. Submission of statement of responsibility management responsibility The BIR has required all taxpayers to attach a statement of management responsibility to the annual income tax return (ITR). The statement affirms the responsibility of taxpayers regarding the content and accuracy of their ITR, including the financial statement and other information returns that accompany the tax return. In the statement, the taxpayer likewise affirms that his/its ITR was prepared in accordance with the financial accounting standards and the provisions of the Tax Code. The statement should be signed by the individual taxpayer, president and managing partner, the Chief Executive Officer and Chief Financial Officer, or any officer performing similar functions regardless of their designation. In the case of a foreign corporation with a branch office in the Philippines, the local manager who is in charge of local operations should affix his/her signature to the statement. The regulations provide that the statement should be attached to all ITRs and information returns to be filed starting from the date of effectivity of the regulations; that is, on March 14, 2010. In case of failure to submit the statement, the taxpayer, upon conviction for each act or omission, shall be punished by a fine or suffer imprisonment or both as prescribed in the Tax Code. (Revenue Regulations No. 03-10, February 26, 2010)

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The regulations likewise mandate all GPPs and their individual partners to signify their intention to claim either the OSD or the itemized deduction by checking the appropriate box in their income tax return filed for the first quarter of their taxable year. Once the election is made, the same type of deduction must be consistently applied for all the succeeding quarterly returns and in the final income tax return for the taxable year. Any taxpayer who is required to file the quarterly income tax return but fails to do so shall be considered as having availed of the itemized deductions option for the taxable year. (Revenue Regulations No. 02-10, February 24, 2010)

March 2010

BIR Issuances
2010 BIR strategy map The BIR has formulated a strategy map that identifies the programs, activities and projects it will undertake for 2010 to attain its revenue goals. The strategy map includes three priority areas, 16 programs, 108 activities and projects, and 10 strategies. The BIRs priority areas include people improvement, process improvement, and taxpayer interaction improvement. As part of its strategy to boost its collections, the BIR shall implement the following measures: 1. High-visibility public awareness campaign on the enforcement and service programs Integrated approach in administering the large taxpayers Re-invigorating the Run After Tax Evaders (RATE) program Enhanced and strategic enforcement approaches Focus on big ticket items More vigorous third-party matching campaign Expanded linkage with key institutions Effective partnership with taxpayers and practitioners Close monitoring of tax eroding measures and investment incentives programs The strategy map also lists the activities and projects that the BIR will implement in support of its programs, which were identified for each of the priority areas. These include, among others, programs to enhance enforcement such as audit of conglomerates, transfer pricing, big-ticket items monitoring, and computer-assisted audit. (Revenue Memorandum Circular 10-10, February 2, 2010) Joint IRR implementing RA 9520, otherwise otherwise known as Philippine Cooperative Code of 2008 The Department of Finance (DOF) has issued the joint rules and regulations that prescribe the guidelines in availing of the tax exemptions granted to cooperatives under RA 9520 (Philippine Cooperative Code of 2008). A. Tax exemption privileges The implementing rules and regulations (IRR) spells out the tax exemption privileges of cooperatives, which vary depending on whether the cooperative deals exclusively with members or not, and the amount of the cooperatives accumulated reserves and undivided net savings in the case of those that also transact business with non-members. Under the IRR, cooperatives that deal with members only shall not be subject to any taxes and fees imposed under the internal revenue laws and other tax laws. These include taxes on transactions of cooperatives with insurance companies and banks, and the 20% and 7.5% final withholding taxes on Philippine and foreign currency bank deposits, respectively. The same tax privileges are enjoyed by cooperatives that transact business with both members and nonmembers and have accumulated reserves and undivided net savings of not more than P10 million. Pursuant to the amendment introduced by RA 9520, the IRR removed the 10-year income tax exemption enjoyed by cooperatives doing business with both members and non-members and having P10 million and more accumulated reserves and undivided net savings under RA 6938. Thus, their business transactions with non-members shall be subject to all applicable internal revenue taxes, but transactions with members shall remain non-taxable pursuant to the joint IRR. Regardless of classification of cooperative, members and shareholders of cooperatives are now exempt from any tax and fee, including DST on their deposits in the cooperative and their patronage refund.

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10. Motivating the BIR workforce

March 2010

BIR Issuances
B. Application for BIR certificate of exemption To enjoy the tax exemption privileges granted under RA 9520, the IRR requires all cooperatives to secure a certificate of exemption/ruling within 60 days from the date of issuance of their certificate of registration from the CDA. For cooperatives registered under the old law (RA 6938), the 60-day period shall be counted from the issuance of a new certificate of registration by the CDA. In case the cooperative is unable to file its application for certificate of registration/ ruling with the BIR within the prescribed period, it shall be subjected to all applicable internal revenue taxes. However, upon issuance of its certificate of exemption/ruling, said cooperative may apply for tax credit/refund of taxes it previously paid from the date of registration with CDA up to the issuance of its certificate of exemption/ruling. The certificate of tax exemption/ruling shall be valid for five years from the date of issue or date of its effectivity as provided in the certificate, and during such period the cooperative is in good standing as certified by the CDA on an annual basis. (Revenue Memorandum Circular 12-10, February 12, 2010) Project BIR RIP Project To maximize estate tax collections, the BIR has launched the project Rest in Peace (RIP), which shall monitor potential tax cases by establishing linkages with private and public institutions to gain access and secure information about decedents. The Revenue District Office (RDO) shall be responsible for establishing linkages with and securing records from civil registers, hospitals, memorial parks, cemeteries, funeral parlors, crematoriums, judicial clerks of courts, obituaries, life insurance companies and other financial institutions. All information gathered shall be submitted to the Audit Information Tax Exemption and Incentives Division (AITEID) for centralized data warehousing. The RDO having jurisdiction over the decedents principal residence shall send a notification letter to the relatives of the decedent regarding the requirements and due dates for filing of notice of death, the estate tax return, and the payment of the estate tax. If the relatives of the decedent fail to file the estate tax return or pay the estate tax due, the RDO shall undertake the necessary action to determine the estate tax obligation of the decedent and to protect the interest of the BIR. On the other hand, the National Investigation Division (NID) shall be responsible for tracking the obituaries in the newspapers of general circulation. The NID shall prepare a weekly list of names of the decedents listed in the obituaries to determine who among these are the high potential cases. The NID shall take jurisdiction over the high potential cases and undertake the same process of notifying and reminding the relatives of the decedent about their obligation to file and pay the estate tax. On the other hand, upon submission of the NID of the list of decedents, AITEID shall ascertain the RDO that should have jurisdiction over the cases not considered high potential, and transmit the same to the RDO within five days from receipt of list from the NID. (Revenue Memorandum Order No. 10-10, February 2, 2010)

March 2010

BIR Issuances
big-ticket Guidelines for monitoring big-ticket items The order prescribes the policies and guidelines on the monitoring, review and determination of tax consequences of big-ticket items (BTI). A transaction is considered a BTI if the amount involved exceeds P200 million. The threshold amount is considered on a per single and unrelated event or transaction basis; it does not take into account the summation or the total of several unrelated and multiple events or transactions. A transaction may also be considered a BTI if it involves a request for a BIR ruling where the amount of the transaction is over P1 million. The information on the occurrence of a BTI shall be sourced from reports published in the newspapers or broadcasted over television and radio stations, announcements and releases in the websites of taxpayers, and disclosures to and/or actions from government regulatory authorities such as the Securities and Exchange Commission (SEC), the Board of Investments (BOI) and the Bangko Sentral ng Pilipinas (BSP). The offices that shall be responsible for monitoring and communicating with the taxpayer/s involved in the BTI within five days from the date of transaction or date of discovery of transaction, are as follows: a. Large Taxpayer (LT) office if transacting parties are a large taxpayer and non-large taxpayer b. Enforcement service if transacting parties are both nonlarge taxpayers c. Commissioner of Internal Revenue if transacting parties are both large taxpayers The concerned BIR office shall send an Access to Records letter to the taxpayer which, if not complied with, would result in the issuance of subpoena duces tecum (SDT). Upon receipt of documents, the BIR shall evaluate the tax consequences of the transaction and determine if the relevant taxes are paid correctly and on time, or if there are tax issues including aggressive tax planning and avoiding schemes implemented by the taxpayer. A letter of authority for a short audit may be issued if a more thorough verification is needed to evaluate the transaction. (Revenue Memorandum Order No. 11-10, February 2, 2010) Minimum gross sales of motels for VAT purposes The order sets the policies and guidelines in determining the output VAT liabilities of establishments like hotels, resorts and motels that offer short time accommodation or allow customers to stay for less than 24 hours. Under the order, owners of motel and other similar establishments are required to submit to the RDO where they are registered, a sworn declaration stating the room type, number of rooms and rate per room of their establishment. These should be submitted within 10 days from the issuance of the order, which falls on February 20 for 2009, and on or before January 31 of each year in the succeeding years. Based on the information on the sworn declaration submitted by the owners, the RDOs are required to prepare an occupancy turnover analysis report (OTAR), which shall contain the prescribed minimum turnover rate, additional sales, and proposed additional output VAT to be paid by motel owners. The RDO shall notify the motel operator of the discrepancy noted in the OTAR and the proposed additional output VAT to be paid by the motel operator for each month, and give it/him the option to amend its/his VAT return, and pay the additional output tax within 10 days upon receipt of notice. Non-amendment of VAT return shall subject the motel to BIR surveillance for a period of 10 days through the issuance of a mission order. A written report will be submitted based on the surveillance activities conducted by the BIR. If the motel is found to have understated its taxable gross sales by 30% or more, the establishment may be subject to Oplan Kandado. Appropriate tax evasion cases under the RATE program may also be filed against the motel. (Revenue Memorandum Order No. 16-10, February 5, 2010)

March 2010

BIR Rulings
Cellular phone allowance Cellular phone allowance ranging from P500 to P2,5000 is granted to supervisory and managerial employees of an ecozone export enterprise engaged in the production of computer and electronic products. This provision allows employees to have frequent communication with the company in order to meet order deadlines. The BIR held that the cellular phone allowance is required by the nature of the jobs and redounds to the convenience and benefit of the companys supervisory and managerial employees. Hence, the phone allowance shall not be included as part of compensation income of the employees subject to withholding tax prescribed under Section 79 of the Tax Code. Neither will it be subject to the fringe benefit tax under Section 33 of the Tax Code, as implemented by RR 03-98, as amended. [BIR Ruling No. DA (ECB-029)733-2009, December 4, 2009] Long-term UITF exempt from 20% FWT Interest income derived by individual citizens and individual resident aliens, as well as non-resident aliens engaged in trade or business in the Philippines, from long-term unit investment trust fund (UITF) that satisfies the conditions for tax-exempt long-term deposits are exempt from 20% final withholding tax under Sections 24(B)(1) and 25(A)(2) of the 1997 Tax Code. The long-term UITF was launched by the bank to give clients access to higher yielding investment instruments, investment diversification and higher yield potential. Under the declaration of trust that governed the establishment of the UITF, the UITF shall be limited to individual trustors and investors who are Filipino citizens or resident aliens. The declaration of trust also provides that the participation in the UITF shall be for a period of at least five years. If participation lasts for less than five years, the interest income shall be subject to a final tax based on schedule contained in Section 24(b)(1) of the Tax Code. Considering that the long-term UITF is in full compliance with the requisites of long-term deposits or investment certificate as defined under Section 22(FF) of the Tax Code, the BIR ruled that the interest income derived from the long-term UITF by individual clients who are Filipino citizens, resident aliens, or non-resident aliens engaged in trade or business within the Philippines, are exempt from 20% final withholding tax. However, the BIR requires the bank to set up a separate numbering system in its books for the long-term UITFs for monitoring purposes. [BIR Ruling No. DA(FIT-025) 836-2009, December 23, 2009] Ascertaining worthlessness Ascer taining worthlessness of bad debts In ascertaining the worthlessness of bad debts, which is one of the requisites for deductibility of bad debts, a taxpayer does not need to go to court to ascertain that the bad debt is worthless. What the taxpayer must show is that it took reasonable steps to collect the debt. If, in the exercise of sound business judgment, the taxpayer believes there is no likelihood of recovery at any time in the future, the debt may already be considered worthless. In the instant case, the company, which is engaged in the marketing, supply and trade of electronic home appliances, and its legal counsel sent demand letters to its buyer in order to collect its accounts receivable. Despite the demand letters, the buyer was unable to fulfill its obligation to pay. Considering that the company took reasonable steps to collect the debt and there appeared to be no likelihood of recovery of the accounts receivable at any time in the future, the BIR deemed the debt worthless, which means the accounts receivable may be written-off and claimed as bad deduction from the companys gross income. [BIR Ruling No. DA(C-296) 727-2009, December 3, 2009]

March 2010

Highlight on P&A services


CTA support CTA litigation support To avoid prolonged trials, we offer independent verification of financial and other pertinent documents that are presented as evidence in tax cases/ disputes or claims for refund before the Court of Tax Appeals (CTA). This involves an evaluation of the completeness and validity of the documents and the correctness of the claims involved or other representations made by the taxpayer based on the requirements provided under applicable laws and regulations.

Tax Brief is a regular publication of Punongbayan & Araullo (P&A) that aims to keep its clientele, as well as the general public, informed of various developments in taxation and other related matters. This publication is not intended to be a substitute for competent professional advice. Even though careful effort has been exercised to ensure the accuracy of the contents of this publication, it should not be used as the basis for formulating business decisions. Government pronouncements, laws, especially on taxation, and official interpretations are all subject to change. Matters relating to taxation, law and business regulation require professional counsel. We welcome your suggestions and feedback so that the Tax Brief may be made even more useful to you. Please get in touch with us if you have any comments and if it would help you to have the full text of the materials in the Tax Brief. Figueroa Lina Figueroa Tax Advisory Principal, Tax Advisory & Compliance Division T +632 886-5511 Ext. 507 F +632 886-5506 Ext 606 E Lina.Figueroa@pna.ph

If you would like to know more about our CTA litigation support services, please contact: Clarissa Hornilla Manager, Tax Advisory & Compliance Division T + 632 886 5511 ext. 525 F + 632 886 5511 ext. 606 E Clarissa.Hornilla@pna.ph

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March 2010