BIR Ruling

June 6, 1975 Messrs. Sycip, Gorres, Velayo & Co. 6760 Ayala Avenue, Makati Rizal Attention: Mr . M . C . Gutierrez Gentlemen : This refers to your letter dated June 4, 1975 submitting to this Office the proposed retirement benefit plan of your client, Philippine Explosive Corporation, covering the non-union employees for pre-determination as to its qualification under R.A. No 4917. In reply, I have the honor to inform you that a close perusal of the proposed written program constituting the Plan, shows that the Plan meets the requirements for a reasonable plan prescribed by the law, as amplified by Revenue Regulations No. 1-68 and, therefore, the benefits provided for in the law may be availed of, such as exemption of the benefits from income tax, exemption of the trust income from income tax and deductibility of company contribution from gross income. Final adjudication of the qualification of the Plan shall, however, be made after you shall have submitted the final written program actuarial assumptions as to costing, trust agreement and BIR Form 17.60 duly accomplished. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5