Perma Marketing Corporation

April 29, 1980 PERMA Marketing Corporation 2nd Floor, Casmer Building 195 Salcedo Street, Legaspi Village Makati, Metro Manila Attention : Mr . Alfredo S . Arboleda Managing Director Gentlemen: This refers to your letter of April 18, 1980 informing us of the plan of a foreign international trading corporation to establish its regional headquarters in the Philippines under P.D. 218 to supervise the activities of its affiliates in the Asia-Pacific region. In this connection, you are seeking our opinion on the following: 1. Whether the parent company which will set up its regional headquarters in the Philippines can itself be located within the Asia-Pacific region, particularly in Singapore? 2. Inasmuch as the parent company in Singapore intends to eventually relocate its offices in HongKong, will the HongKong company have to reapply with the SEC or will the initial SEC approval given to the Singapore company suffice? Our answer to Query No. 1 is in the affirmative. The parent company or multinational company, as the term is used in P.D. 218, may locate its offices in Singapore, within the Asia-Pacific region. As to query No. 2, in the event that the multinational company decides to transfer its office from Singapore to HongKong, there is no need to file another application with the SEC. The old Certificate of Registration and License issued by the Commission authorizing it to establish a regional or area headquarters in the Philippines will still do. However, a petition for the amendment of the license issued to the regional headquarters should be filed with this Commission by the parent company. Please be guided accordingly. Very truly yours, For the Chairman: (SGD.) ROSARIO N. LOPEZ Director Corporate and Legal Department