Monetary Authority of Singapore

May 15, 2008 BIR RULING [DA-289-08] Monetary Authority of Singapore 10 Shenton Way MAS Building Singapore Attention: Ms. Christina Aw Deputy Director Finance Department and Ms. Roxanne Soh Associate Finance Department Gentlemen : This refers to your letter dated September 18, 2007 requesting for a ruling as to whether or not income derived by Monetary Authority of Singapore (MAS) from the sale of its security investments in the Philippines is a tax-exempt transaction. It appears that on November 10, 2003, this Office in BIR Ruling No. DA401-03 ruled that ". . . since as represented the Monetary Authority of Singapore is a financial institution owned, controlled and financed by the State of Singapore as contemplated under Section 32(B)(7)(a)(ii) of the Tax Code of 1997, any income received by Monetary Authority of Singapore from its investment in the Philippines, such as interest on loans, interest on deposits, interest on bonds, dividends, and capital gains on sale of shares of stock, bonds, and other domestic securities, are exempt from Philippine income tax and consequently from withholding tax. (BIR Ruling No. DA130-02 dated July 31, 2002)." Accordingly, this Office holds that income derived by MAS from the sale of its investments in the Philippines is not subject to Philippine income tax and consequently to withholding tax. 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. HTCISE Very truly yours, (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service