Beatrix S. Anagaran

September 23, 2009 July 8, 2009 BIR RULING [DA-(S270-004) 565-09] Beatrix S. Anagaran OIC, General Business and Investment Department Subic Bay Metropolitan Authority Subic Bay Freeport Zone Dear Ms. Anagaran, This refers to your letter dated May 27, 2009 requesting for copies of the Audited Financial Statements of Hualong International, Inc. for the years 2004-2008 for litigation and investigation purposes. In reply, please be informed that the requested documents contain information regarding the business and/or income of taxpayers which are considered confidential under Section 270 of the National Internal Revenue Code of 1997 (NIRC). The pertinent provision reads: "Sec. 270. Unlawful Divulgence of Trade Secrets. Except as provided in Section 71 of this Code and Section 26 of Republic Act No. 6388, any officer or employee of the Bureau of Internal Revenue who divulges to any person or makes known in any other manner than may be provided by law information regarding the business, income or estate of any taxpayer, the secrets, operation, style or work, or apparatus of any manufacturer or producer, or confidential information regarding the business of any taxpayer, knowledge of which was acquired by him in the discharge of his official duties, shall, upon conviction for each act or omission, be punished by a fine of not less than Fifty thousand pesos (P50,000) but not more than One hundred thousand pesos (P100,000), or suffer imprisonment of not less than two (2) years but not more than five (5) years, or both." cDACST In view of this, we regret to inform you that we cannot furnish your office copies of the Audited Financial Statements of Hualong International, Inc. for the years 2004-2008 as the same is prohibited under Section 270 of the NIRC. Very truly yours, (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service