BIR Ruling

October 23, 1967 Messrs. Ross, Salcedo, Del Rosario Bito & Misa P.O. Box 781, Manila Gentlemen : This refers to your letters dated August 25, 1967 and September 12, 1967 requesting a ruling as to the tax consequences of the merger of the Getty Oil Company, Mission Development and Tidewater Oil Company, all foreign corporations organized under the laws of the State of Delaware, U. S. A. cdtech In reply, I have the honor to inform you as follows: Of the three merging corporations, Tidewater Oil Company appears to be the only one duly licensed to engage in business in the Philippines. As the merger does not result in the liquidation of the Philippine business, no resulting tax consequence will arise in so far as Philippine taxes are concerned regardless of the treatment accorded to the merger in the jurisdiction where affected. For as long as the Philippine assets and operations remain undisturbed, the merger will produce no other consequence in the Philippines except the assumption by the surviving corporation of the Philippine business which fact may simply have to be registered with the Securities and Exchange Commission. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue