Recycling Corporation of the Philippines, Inc.

August 28, 2009 VAT RULING NO. 012-09 Recycling Corporation of the Philippines, Inc. 1 Cherry Street San Juan, Taytay, Rizal Attention: Mr. Manuel N. Lim President Gentlemen : This refers to your letter dated October 9, 2008, requesting that your corporation, Recycling Corporation of the Philippines, Inc., be exempted from the payment of value added tax imposed by Title IV of the 1997 National Internal Revenue Code (Tax Code). Based on the SEC registration papers you have attached to your request letter, your company is a domestic corporation, whose primary purpose is to engage in the manufacture, processing, production, smelting, refining and or alloying and in the trading, marketing or general merchandising, at wholesale or retail of iron ores, silica, lead, zinc, copper, antimony, tin and all kinds of ores, etc. Said company is registered with the Securities and Exchange Commission on November 14, 1995 under SEC Reg. No. AS095-001385. cAHITS In reply, please be informed that a close perusal of your activities as have been authorized and registered with the SEC show that the same are undertakings which do not fall under the activities which are exempt from VAT under Section 109 of the Tax Code, as amended. As such, we regret to deny your request to be exempt from the payment of VAT, for lack of legal basis. Very truly yours, (SGD.) GREGORIO V. CABANTAC Deputy Commissioner