Hi-Precision Steel Center, Inc.

April 13, 2007 BIR RULING [DA-230-07] DA 101-06 Hi-Precision Steel Center, Inc. PTC-SEZ Bo. Maduya Carmona, Cavite Attention: Ms. Joann A. Oriondo Finance Manager Gentlemen : This refers to your letter dated October 12, 2006 stating that your company, Hi-Precision Steel Center, Inc., is a Philippine Export Processing Zone (PEZA) registered enterprise with Registration Certificate No. 02-235 dated July 1, 2002; that it is engaged in the production/processing of steel sheets, slit coils and various steel products and operations as steel service center for practically all types of industries requiring precisely cut steel sheets and slit coils. Based on the foregoing representations, you now request for exemption from the payment of withholding tax pursuant to Section 2.57.5 (B) (2) of Revenue Regulations No. 2-98, as amended. cCSTHA In reply thereto, please be informed that Section 2.57.5 of Revenue Regulations No. 2-98, as amended, provides: "SEC. 2.57.5. Exemption from Withholding . The withholding of creditable withholding tax prescribed in these Regulations shall not apply to income payments made to the following: (B) Persons enjoying exemption from payment of income taxes pursuant to the provisions of any law, general or special, such as but not limited to the following: xxx xxx xxx (2) Corporations registered with the Board of Investments and enjoying exemption from the income tax provided by Republic Act No. 7916 and the Omnibus Investment Code of 1987; SUCH BEING THE CASE, this Office holds that payments made by your customers are not subject to the creditable withholding tax pursuant to Section 2.57.5 of Revenue Regulations No. 2-98. ESTCDA This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. Very truly yours, (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service