BIR Ruling No. 291-2020

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE

BUREAU OF INTERNAL REVENUE

Quezon City

SN:MSLA-0291-2020

CERTIFICATION

particularly the Master Securities Lending Agreement with MSLA Ref. No. THIS IS TO CERTIFY that, on the basis of the representations and documents submitted. xecuted on January 28, 20191, the original of which is attached hereto and made an integral part hereof, the

delivery of the collateral appurtenant thereto, are not subject to capital gains tax (CGT), stock borrowing and lending of securities within the borrowing period not exceeding two years, and the transaction tax and documentary stamp tax (DST).

The said MSLA is executed by and between:

Pasig City 1605, as the LENDER, represented herein by Melanio C. Dela Cruz and Sheila Marie C. Aguilar, ABACUS SECURITIES CORPORATION (TIN: ( address at Unit 2904-A East Tower, PSE Centre, Exchange Road, Ortigas Center ) with business

-and

Salvador. address at 23/F Tower One, Ayala Triangle, Ayala Avenue, 1226 Makati City, as the BORROWER, represented herein by Emmanuel O. Bautista and Mark Anthony P. DEUTSCHE REGIS PARTNERS.INC. (TIN: with business

to the penalties provided for under Sections 248 and 249 of the same Code, as implemented by the National Internal Revenue Code of 1997, as amended. Moreover, the transaction shall also be subject outstanding and liquidated Securities Borrowing and Lending (SBL) Transactions and Stock Returns within the period provided for under Revenue Regulations (RR) No. 10-2006, as amended by RR No. 001-2008. Violation of this requirement shall subject the transaction to taxes imposed under Sections 24(C), 25(A)(3), 28(A)(7)(c), 28(B)(5)(c), 127(A) as applicable, and Section 1752 of the said regulations. The Lender/Agent and Borrower/Agent are required to submit bi-annual summary reports of

for misrepresentation or for violations of the conditional requirements set forth in Sections 244 and 245 of the National Internal Revenue Code of 1997, as amended, and in RR No. 10-2006, as amended. UNFSIMNY WHREOr. I have heremnto se my hand.his This Certification shall be vaiid unless sooner suspended, cancelled, or revoked by this Office 02U day of

cusomy

Registration Fee of FIVE THOUSAND PESOS (P5,000.00) was paid on February 13,2019 under Official Receipt No. OR2019-004823-000451 Commissioner of Internal Revenue CAESAR R.DULAY 034120

-K-1-LMAT

2 As a result of the amendments introduced by Republic Act RA) No. 9243. Section 176 was amended and renumbered to Section Acknowledged on February 01,2019 175.