IdeaCorp, Inc.

May 19, 2009 BIR RULING [NSNP-(S30E-056) 321-09] NSNP; S-30 (E); S-30-023-99 IdeaCorp, Inc. 23 Pres. Quezon Avenue Industrial Valley Complex Marikina City Attention: Ms. Rae Rivera Corporate Secretary Gentlemen : This refers to your letter dated July 2, 2008 requesting exemption from the payment of income tax pursuant to Section 30 (E) of the Tax Code of 1997, as amended. Documents submitted show that IdeaCorp, Inc., with Taxpayers Identification No. 006-713-343-000, is a non-stock, non-profit organization duly registered with the Securities and Exchange Commission (SEC) under SEC Registration No. CN200705837 dated April 18, 2007. The purposes for which it was organized are as follows: "To conduct, engage in and facilitate research on development, economic, social and governance issues including but not limited to the role of information and communications technology (ICT) in government, economy, business, society and global affairs; providing policy advice and training to public and private institutions, organizations and individuals; advocating and disseminating research, study results and position papers on the aforementioned areas of study in digital form or otherwise; and utilizing and facilitating all resources, acquired by means of donation, contribution or grant, for the accomplishment of all abovementioned purposes, not to be used for profit, and including the enjoyment of such powers necessary, incidental or convenient to the accomplishment thereof." In reply, please be informed that this Office cannot as yet issue the requested ruling/certificate of tax exemption because IdeaCorp, Inc. has to prove by actual operation for at least three (3) years that it is really an organization/association exempt from income tax under Section 30 of the Tax Code of 1997, as amended. IdeaCorp, Inc. can file the necessary annual information return instead of an income tax return on or before the 15th day of the fourth month of the preceding accounting period following the start of its operation as an exempt organization as required under Section 24 of Revenue Regulations No. 2 ( Collector vs. Sinco, G.R. L-9276 dated October 23, 1956). HcSDIE Based on such information return, we shall conduct the necessary investigation on the activities undertaken by IdeaCorp, Inc. during the period. The determination letter of exemption shall thereafter be issued depending upon the result of our investigation. However, IdeaCorp, Inc. is subject to the corresponding internal revenue taxes imposed under the Tax Code of 1997, as amended, on its income derived from any of its properties real or personal, or any activity conducted for profit regardless of the disposition thereof, which income should be returned for taxation. Likewise, interest income from currency bank deposits and yield or any other monetary benefit from deposit substitute instruments are subject to 20% final withholding tax as well as its interest income under the expanded foreign currency deposit system which are subject to a final withholding tax of 7 1/2% pursuant to Section 27 (D) (1) in relation to Section 57 (B) of the Tax Code of 1997, as amended. Moreover, it is required to file on or before the 15th day of the fourth month of the preceding accounting period a Profit and Loss Statement and Balance Sheet with Annual Information Return under oath, stating its gross income and expenses incurred during the year and a certificate showing that there has not been any change in its By-Laws, Articles of Incorporation, manner of operation and activities as well as sources and disposition of income. It should be understood that IdeaCorp, Inc. shall be constituted as withholding agent of the government if it acts as an employer and any of its employee receives compensation income subject to withholding tax, or if it makes income payments to individuals or corporations subject to the expanded withholding tax provided for in Section 57 (B) of the Tax Code of 1997. (BIR Ruling No. S-30-023-99 dated March 15, 1999) 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. TcSCEa Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service