Laguna Technopark

January 22, 1993 BIR RULING NO. 048-93 LAGUNA TECHNOPARK 50 (h) 000-00 048-93 Laguna Technopark, Inc. Makati Stock Exchange Building 6767 Ayala Avenue Makati, Metro Manila Attention: Atty . Renato O . Marzan This refers to BIR Ruling No. 50(b)-00-00-206-91 dated October 4, 1991, to the effect that your sale of industrial lots within the industrial estate in Bian and Sta. Rosa Laguna is not subject to the creditable withholding tax of 2.5%. cdtech Please be informed that after a re-study of the pertinent facts, this Office believes that you are neither a producer nor manufacturer of specific products and commodities under Article 16 and 18, in relation to Article 28 of the Omnibus Investments Code (Executive Order No. 226); and that the listing of your activity of selling industrial lots in the Investment Priorities Plan is doubtful because it is not related to the production of specific products and commodities, as indicated under Articles 26 and 28 of same Code. In view thereon, and considering the fact that the Department of Justice has rendered an opinion (Opinion No. 122, s. 1992 dated September 21, 1992) declining to rule on the issue of your eligibility to be registered with the Board of Investments as a preferred non-pioneer enterprise, BIR Ruling No. 50(h)-000-00-206-91 dated October 4, 1991 is hereby revoked. It is understood, however, that the revocation is prospective; hence, it will not affect your transaction between October 4, 1991 and the issuance of this ruling. cdt JOSE U. ONG Commissioner of Internal Revenue