SAMSUNG SDS GLOBAL SCL PHILIPPINES CO., LTD. INC., v. COMMISSIONER OF INTERNAL REVENUE

111111111111 1111 1111111111111111111111111111111111111111111111 111111111111111111 CTA Fonn No. 8 23-000152-0062 REPUBLIC OF THE PIDLIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL FIRST DIVISION CTA CASE N0.11129 SAMSUNGSDSGLOBALSCL PIDLIPPINES CO., LTD. INC, Petitioner, -versus- NOTICE OF AMENDED DECISION COMMISSIONER OF INTERNAL REVENUE, Respondent. To: OFFICE OF THE SOLICITOR GENERAL 134 Amorsolo Street, Legazpi Village Makati City ATTY. FELIX PAUL R. VELASCO III ATTY. SYLVIA R. ALMA JOSE ATTY. AYESHA HANlA B. GUILING-MATANOG Bureau of Internal Revenue Room 703, Litigation Division, BIR National Office Building Sen. Miriam P. Defensor-Santiago Avenue Diliman, Quezon City GALVEZ CARDINO PAYUMO LAW OFFICES Unit 77B, A VR Building Beaterio Street, Intramuros 1002 Manila GREETINGS: You are hereby notified by these presents that on October 1, 2026, an Amended Decision was rendered in the above-entitled case, copy of which is attached hereto. Quezon City, Philippines, October 1, 2026.

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL FIRST DIVISION SAMSUNG SDS GLOBAL CTA CASE NO. 11129 SCL PHILIPPINES CO., LTD. INC., Members: Petitioner, BACORRO-VILLENA, Acting Chairperson, and CUI-DAVID, JJ. -versus - COMMISSIONER OF Promulgated: INTERNAL REVENUE, Respondent. SEP 2 9.. 2026; f)$P/JJ X - - - - - - - - - - - - - - - - - - - - - - - - - - - - t:- .:-:;:r - - - - - - - - - - - - - - - - X AMENDED DECISION CUI-DAVID, J.: Submitted for the Court's resolution is petitioner's Motion for Reconsideration (Re: Decision dated 22, [sic] January 2026) [Motion], mailed on February 13, 2026, and received by the Court on February 20, 2026, with respondent's Comment and Opposition [Re: Petitioner's Motion for Reconsideration (Re: Decision dated 22 January 2026)], filed on March 25, 2026 . On January 22, 2026, the Court promulgated a Decision denying petitioner's claim for refund of unutilized creditable withholding taxes (CWTs) of P30,208,50 1.64, for failure to sufficiently establish that the income payments from which the claimed CWTs were withheld were included in its gross income as reported in its Annual Income Tax Return (AITR) for calendar year (CY) 2020 . The dispositive portion of the assailed Decision reads: "WHEREFORE, in light of the foregoing considerations, the present Petition for Review is DENIED for lack of merit. SO ORDERED."

AMENDED DECISION CTA Case No. 11129 Samsung SDS Global SCL Philippines Co. , Ltd. Inc. v. Commissioner of Internal Revenue x---------------------------------------------------------------------------------------------------------x In its Motion, petitioner assails the Court's finding that it failed to establish that the income payments upon which the claimed CWTs were withheld were reported as part of its gross income in its AITR, as such, it failed to satisfy the third requisite for the entitlement of its claim, i.e., that the income upon which the taxes were withheld must have been included in the income tax return of the recipient. Petitioner recalls that the amount totaling P1 ,449,533,227.67 as income payments was disallowed by the Court since it failed to prove that the amount was reported as part of its gross income based on: the SAP Extracted Sales lacked the sum totals (the SAP total revenues could not be confirmed); and, the income tracing schedules (referencing Exhibits "P-38" and "P-39") prepared by the Independent Certified Public Accountant (ICPA) did not specifically identify the sub-marked exhibits referenced therein, thereby preventing the confirmation and verification of the amounts traced and included in the schedules. Petitioner asserts that the Court's Decision imposed extra-statutory procedural requirements for income inclusion which it argues is contrary to the National Internal Revenue Code (NIRC) of 1997, as amended, and controlling Supreme Court doctrine on the matter. Petitioner claims that the NIRC of 1997, as amended , does not prescribe a specific accounting- report format or exhibit labeling scheme as a condition for due course. Citing the case of Tullett Prebon (Philippines), Inc. v. Commissioner of Internal Revenue, 1 petitioner states that there is no prescribed evidence to prove income inclusion and that the standard quantum is preponderance of evidence. Petitioner contends that the proper judicial approach is to evaluate the evidence on record cumulatively-not to deny the entire claim based on perceived insufficiency in one report's formatting or one cross-referencing style. Thus, petitioner submits that the Court should allow clarificatory submissions where the crux of denial rests on the alleged insufficiency of cross-r eferences, and that, to assist in the verification, the ICPA submitted to this Court a Letter dated February 13, 2026 describing the procedures performed 1 G.R. No. 2572 19, July I 5, 2024 [Per J. Dimaampao, Third Division].

AMENDED DECISION CTA Case No . 11129 Samsung S DS Globa l SCL Ph ilippines Co., Ltd. Inc. v. Commis sion e r of Internal Reven ue x---------------------------------------------------------------------------------------------------------x in tracing the income payments subject to CWT to the gross income reported in petitioner's AITR for CY 2020.2 On the other hand , respondent maintains that the Court correctly ruled that petitioner failed to establish that the income payments amounting to Pl,449,533,227.67, from which the claimed CWTs arose , were included in its gross income for CY 2020 . Hence, respondent insists that petitioner failed to satisfy the third requisite for a claim for refund of excess unutilized CWTs. Respondent further reiterates his position that petitioner failed to exhaust administrative remedies before elevating the case to the Court. Consequently, respondent insists that the present Petition for Review was prematurely filed considering that petitioner's administrative claim for refund of CWT remained pending investigation and evaluation before the Bureau of Internal Revenue (BIR) . After due consideration, the Court finds partial merit in petitioner's Motion. As previously discussed, the third requisite for a valid claim for refund or tax credit of excess unutilized CWTs requires proof that the income upon which the taxes were withheld was included in the return of the payee or recipient. Correspondingly, for its CWT refund claim to prosper, it is incumbent upon petitioner to prove that the income payments corresponding to the claimed CWTs were indeed declared as part of its income in its AITR for CY 2020. To recall in the assailed Decision, the Court considered and examined petitioner's Annual Financial Statements (AFS) , AITR, and other relevant documents, together with the submitted ICPA Report and its related schedules, as follows: 1. AFS for CY 2020;3 2. AITR for CY 2020;4 3. SAP Extracted Sales;s 4. Cello System Extracted Data;6 2 " Letter in response to the Honorable Court 's decision in denying the Petitioner 's Petition for Review on its application for refund of P30,208,502.00. representing alleged unutilized creditable withholding taxes (CWTs) for calendar year 2020 " dated February 13, 2026, attached in petitioner's Motion for Reconsideration. 3 Exhibit "P50", Note 13, Page 23 of 47, USB (Exhibit "P-26-2"). 4 Exhibit "P-5-4", Li ne 27, Docket- Vol. I, p. 69. s Exhibits "P-36-1" to "P-36-1 4". USB (Exhibit "P-26-2"). 6 Exhibits "P-38-1,. to "P-38-1 2" and "P-39-1 " to "P-39-8", USB (Exhibit "P-26-2").

AMENDED DECISION CTA Case No . 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal Revenue x---------------------------------------------------------------------------------------------------------x 5. Samsung Electronics Philippines Co. (SEPCO)-Provided Schedule of Income Payments from which Taxes were Withheld;7 6 . Samsung Electro-Mechanics Philippines Corporation (SEMPHIL)-Provided Schedule of Income Payments from which Taxes were Withheld;B 7. Cello System Extracted Freight Billing Invoices for SEPCQ;9 8. Cello System Extracted Freight Billing Invoices for SEMPHIL; Io 9. Schedules of income payment tracing from SEPCO- provided schedule to the Cello System; ll and 10. Schedules of income payment tracing from SEMPHIL- provided schedule to the Cello System. 12 Upon evaluation of the foregoing documents, the Court found that the revenues reported in petitioner's AFS for CY 2020 in the amount of P2,627 ,090, 744.00 tallied with those reported in its AITR for the same year. The Court likewise took note of the ICPA's explanation regarding petitioner's use of the Cello Billing Management System (Cello System) for its logistics transactions. However, in verifying the income payment tracing, the Court found that the SAP Extracted Sales, which contains the logistics revenues per SAP books and ranges Exhibits "P-36-2" to "P-36-14 ," did not reflect the calculated totals or summations for each, thus, preventing the confirmation of whether the amounts reflected therein corresponded to the alleged revenues of P2,625,573,211.32 purportedly carried over to the revenues reported in the AFS. The Court further observed that the ICPA's schedules of income tracing (Annexes 5-7 and 14-16) indicated only Exhibits "P-38" or "P-39 ," albeit actually ranging from Exhibits "P-38-1" to "P-38-12" and "P-39-1" to "P-39-8", as reference for the Cello System Extracted Data, to which the ICPA allegedly traced the income payments from the SEPCO and SEMPHIL- provided schedules, thereby, preventing the verification of the amounts traced by the ICPA to the Cello System Extracted Data. 7 Exhibit " P-40", USB (Exhibit " P-26-2"). 8 Exhibit "P-75", USB (Exhibit " P-26-2''). 9 Exhibits " P-37-1 " to " P-37-9", USB (Exhibit " P-26-2"). 10 Exhibits " P-69-1 " to " P-69-12", USB (Exhibit " P-26-2"). 11 Annexes 5, 6 and 7 of ICPA Report (Exhibit " P-26"), USB (Exhibit " P-26-2"). 12 Annexes 14, 15 and 16 of ICPA Report (Exhibit " P-26" ), USB (Exhibit " P-26-2" ).

AMENDED DECISION CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal Revenue x---------------------------------------------------------------------------------------------------------x Clearly, the Court did not prescribe any particular format for the presentation of the income tracing, nor did it deny petitioner's claim outright merely because of the absence of sum totals and specific exhibit sub-references, without considering the relevant supporting documents presented. Rather, the conclusions reached in the Decision were based on the evidence presented by petitioner in support of its claim. No particular document or prescribed format was required to establish the income payment tracing. The Court duly examined the relevant supporting documents and schedules to determine whether the income tracing performed by the ICPA could be independently verified. Significantly, substantiating the CWTs is a requirement separate and distinct from income tracing. Thus, even if the CWTs amounting to P30,208,502.00 were found to have been duly substantiated, petitioner was still required to establish that the corresponding income payments were included in the gross income reported in its AITR. Accordingly, the !CPA's findings on income tracing could not simply be accepted without sufficient supporting information that would enable the Court to verify them independently. Moreover, the Court's requirement that the relevant schedules reflect their sum totals and specific exhibit references does not amount to prescribing a particular form of evidence or manner of presentation to establish income inclusion. What the Court required-and what petitioner initially failed to provide-was sufficient information to enable the verification of its claim. The sum totals merely represent the aggregate amounts reflected in the submitted schedules and should have been indicated by the !CPA to support its conclusion that such schedules accounted for the alleged revenues of P2,625,573,211.32. Likewise, the specific exhibit sub-markings merely identify the precise portions of the Cello System Extracted Data to which the !CPA allegedly traced the corresponding amounts. If the amounts were indeed traced to such data, the specific supporting exhibits should have been clearly identified. To address the foregoing deficiencies, petitioner submitted the !CPA's explanation and clarification of the procedures employed in tracing the income subject to CWT to the gross income reported in petitioner's AITR for CY 2020, as

AMENDED DECISION CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. In c. v. Commissioner of In ternal Revenue x---------------------------------------------------------------------------------------------------------x set forth in the !CPA's letter dated February 13, 2026. 13 Accompanying the letter was a USB dated February 20, 2026 , containing the SAP Extracted Sales 14 and the Cello System Extracted Data, l S now reflecting the corresponding sum totals, as well as the schedules of income tracing (Annexes 5-7 and 14-16) containing detailed exhibit references. Considering tha t no new exhibits were offered and that the submissions merely clarify the evidence already on record, the Court shall consider the !CPA's explanation in resolving petitioner's Motion for Reconsideration. A perus al of the !CPA's findings16 shows that p etitioner's total revenues per SAP books amounted to P2,627,090,744.21 , consisting of logistics and non-logistics r evenues, as follows: Exhibit Particulars Sum Totals Numberl7 Sales-Export Truck Transp ortation "P-36-2" p 240,300.00 Sales-Export Amount-Ma rine "P-36-3" 2,634,063.56 Tran sportation Sales-Export Amount-Air "P-36-4" 1,010,672,596 .95 Tra n s portation Sales -Import Amount-Marin e "P-36-5" 264,104,382 .66 Tra n s portation Sales -Import Amount-Air "P-36-6" 394,683,650.77 Tra n s2ortation Sales-Import Amoun t -Subcontr actors "P-36-7" 1, 148,0 15 .03 Sales -Wareh ou se-Storage "P-36-8" 225,238,482 .6 9 Sales-Wareh ouse-Produ ct "P-36-9" 176,527,667.92 Mana ge m ent Sales-Wareh ou se-VAS "P-36- 10" 11 ,282,877.77 Sales-Inland-Truck Tran sportation "P-36- 11" 465,996,466.66 Sales-Inland-Shipmen t "P-36-12" 33,97 0,682.75 Sales-Inla nd-Air Transportation "P-36-13" 37 '799' 166.46 Sales Revenue - In land - Cou rier "P-36-14" 1,274,858 . 10 Total Logistics Revenu es 2 ,625,573,2 1 1.32 Non -logistics Revenues (Sales-Service- P-36 - 1 1,517,532 .89 PJ T) Total Revenues per SAP Books P2,627 ,090, 744.21 13 Docket - Vol. II, pp. 864-880. 14 Exh ibits " P-36- 1" to " P-36- 14 ." 15 Exh ibits "P-38- 1" to "P-38-1 2" and "P-39- 1" to "P-39-8". 16 Annex 3 of !CPA Report (Exhibit "P-26"), US B (Exhibit "P-26-2"); !CPA letter dated Feb. 13, 2026, Docket - Vol. II, pp. 875- 876. 17 USB dated February 13, 2026.

AMENDED DECISION CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal Revenue x---------------------------------------------------------------------------------------------------------x While th e foregoing breakdown now confirms petitioner's revenues p er SAP books, with th e total amount of P2,627,090,744.21 substantially tallyin g with the P2,627 ,090, 744.00 in r evenues reported in petitioner's AFS and AITR for CY 2020 , this alone does not establish compliance with the income-tracing requirement. Petitioner must still establish tha t the revenues recorded in its SAP books include th e income payments amounting to P1,449,533,227.67, upon which the substantiated CWTs of P30,208,501.64 were withheld. To support this, the ICPA validated that income payments from logistics services rendered to SEPCO and SEMPHIL, totaling P1,239,250,985.04 and corresponding to CWTs of P25,939,959.23, were tra ced to the Cello System and SAP books. The summary of the !CPA's findings is reproduced below, a s follows: 18 Traceable Revenue Reference to Particulars Amounts to Cello CWT ICPA Report i9 System Sales to SEPCO a . Incom e p ayments per SEPCO- provided s ch edu le are equ al to th e Annex 5 P635,52 1,6 15.01 P 13 ,85 1,929.0 5 amounts per Petition er's Cello System b . Income p ayments per SEPCO- provided sch edule are greater than A nnex 6 4 ,097,4 73 .37 82,6 15.50 th e amoun ts p er Petitioner's Cello System c. Incom e payments p er SEPCO- provided sch edu le are less than the Annex 7 4 ,767, 184 .92 108,360.45 amounts p er Petitioner 's Cello System Subtotal P644,386,273.30 p 14,042,905.00 Sales to SEMPHIL a . Incom e paymen ts per SEMPHIL- p rovided sch edule are equ al to the 2,343,8 2 1.6721 Ann ex 14 117' 19 1,083.50 20 amounts p er Petition er's Cello System b . In com e payments p er SEMPHIL- provided sch edu le are greater than 233,69 7 ,84 1.53 4 ,67 3,7 16 .83 Annex 15 th e amounts p er Petitioner 's Cello System 18 JCPA Report (Exhibit "P-26"), Docket - Vol. II, pp. 596 and 598. 19 USB dated February 13, 2026. 20 Apparently, the amount of !" 151, 19 1,053.00 was erroneously indicated in the table under "Traceable Amounts to Cello System" co lumn per IC PA Report sum maries. Per Annex 14, only the amo unt ofP I1 7, 19 1,083.50 pertains to traced Revenues, and the remaini ng amount of 1"33,999,969.50 pertains to Pass-through Charges, which the ICPA admitted as not traced due to insufficiency of data (see ICPA Report [Exhibit "P-26"], Docket - Vol. !1, pp. 597 to 598). 21 2% of P II 7, 19 1,083.50 (following the CWT computation per Annex 14).

AMENDED DECISION CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal Revenue x---------------------------------------------------------------------------------------------------------x c. Income payments per SEMPHIL- provided schedule are less than the Annex 16 243,975,786.71 4,879,515.73 amounts per Petitioner's Cello System Subtotal P594, 864, 711 . 74 p 11 , 897, 054.23 Total P 1,239,250,985.04 P25,939,959.23 Upon further verification , however, the Court finds that, out of the P1,239,250,985.04 in income payments reported by the ICPA as having been traced, income payments amounting to P8,849,242.41 , corresponding to CWTs of P176,984.84, were not shown to form part of the revenues recorded in the Cello System and SAP b ooks and u ltimately carried over to th e revenues r eported in petitioner's AFS and AITR for CY 2020. The details of the amount of P8,849,242.41 and its corresponding CWTs of P176,984 .84 are broken down hereafter as follows: Per I CPA income tra c ing Per Court's fu rth er verific ation Rev enue s pe r Traced to Co rrespon ding SEPCO- Ce llo Syst e m Income CWTof provid e d ICPA Extra cte d p ay m ent not Billin g in c ome schedule traced Report Data/ SAP Exhibit No. t race d Ref. No. paym e n t not to Cello Re ference23 Ex t rac ted (c =a-b) t ra c e d 22 System. S ales (a) (b) "P-38-9" page 3; 30011 p 127,106.51 Annex 5 p 111,187.59 "P-36-11" page p 15,918.92 p 318.38 94 "P-38-11" pa ge 1; 30027 1,573.44 Annex 5 9 75.00 598.44 11.97 "P-36 - 13" page 18 "P-38-9" page 98 &99 ; 29984 308,235.15 Annex 5 62,071 .35 246,163.80 4,923.28 "P-36-11" page 92 & 93 "P-38-9" page 3; 30069 3,667.1 5 Annex 5 298.15 "P-36 - 11" page 3,369 .00 67.38 100 "P-38-9" page 20; 30070 26,743 .54 Annex 5 15,555.03 11,188.51 223.77 "P-36 -1 1" p age 100 & 101 "P-38-9" page 48 &49; 30074 3,956.47 Annex 5 2 ,370.07 1,586.40 31.73 "P-36- 11" page 101 "P-38- 11" page 35; 30099 275,486.82 Annex 5 179,097.62 96 ,389.20 1,927.78 "P-36- 13" pa ge 32 & 33 "P-38-9" pa ge 30196 5,808.95 Annex 5 4,422 .11 110; 1,386.84 2 7.74 "P-36- 11" page 22 Computed using 2% of the income payment, following the rate used in the Annexes. 23 USB dated February 13, 2026

AMENDED DECISION CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd . Inc. v. Commissioner of Internal Revenue x---------------------------------------------------------------------------------------------------------x 162 "P-38-9" pages 109 to 110; 30217 7,481.31 Annex 5 4,211.13 3,270.18 65.40 "P-36 - 11" page 162 & 163 "P-38-9" page 11 1; 302 18 27,343.94 Annex 5 22,431.85 4,912.09 98.24 "P-36-11" page 163 "P-38-9" page 110; 30249 22,051.77 Annex 5 20,303.98 1,747.79 34.96 "P-36-1 1" page 173 "P-38-9" page 113; 30250 1,036. 16 Annex 5 211.60 824 .56 16.49 "P-36-11 " page 173 "P-38-9" page 191; 30293 162,555.37 Annex 5 138,224.92 24 ,330.45 486.61 "P-36-11" page 271 & 272 "P-38-9" page 193; 30294 506,938.74 Annex 5 79,308.59 427,630 .15 8,552.60 "P-36-1 1" page 272 (not traced to "P- 30369 30,126.56 Annex 5 - 3 8 -9" page 207) 30,126.56 602.53 "P-38-9" page 207; 30340 33,062.09 Annex 5 554.04 32,508.05 650. 16 "P-36-11" page 302 "P-38-9" page 207; 30380 1,359.33 Annex 5 464.76 894.57 17.89 "P-36-11" page 32 1 "P-38-9" page 240 & 241; 30332 362,102.42 Annex 5 146,466.72 2 15,635.70 4,312.71 "P-36-11" page 274 & 275 "P-38-9" page 247; 30439 358,242.36 Annex 5 107,512.05 250,730.3 1 5,0 14.61 "P-36-11" page 364 & 365 "P-38-9" page 243 ; 30388 476,682.52 Annex 5 166,984.09 309,698.43 6,193.97 "P-36- 11" page 322 & 323 "P-38-9" page 246 & 247; 30438 714,751.47 Annex 5 130,792.32 583,959 .1 5 11 ,679.18 "P-36-11" page 364 & 365 "P-38-11" page 62; 30279 954 .00 Annex 5 92.00 862.00 17.24 "P-36- 13" page 57 "P-38-1 1" page 92; 30559 174,508 .82 Annex 5 109,849.29 64,659 .53 1,293. 19 "P-36- 13" page 94 "P-38-7" page 1; 30640 1,850,903.53 Annex 5 638,383 .35 1,2 12,520.18 24,250.40 "P-36-9" page 3 "P-38-9" page 415; 30794 243,542.23 Annex 5 22,824.52 220,7 17.71 4,4 14.35 "P-36-11" page 619

AMENDED DECISION CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal Revenue x---------------------------------------------------------------------------------------------------------x "P-38-9" page 377; 30686 49,716.31 Annex 5 14,823.00 34,893.31 697.87 "P-36- 11" page 556 "P-38-9" page 414; 30693 79,367.92 Annex 5 4,408.84 74,959.08 1,499.18 "P-36-11" page 558 "P-38- 11" page 119; 31164 392 ,073 .94 Annex 5 3,1 16.04 388,957.90 7,779.16 "P-36-13" page 120 "P-38-11" page 119; 31165 466,163.54 Annex 5 25 1,714.60 214,448 .94 4,288.98 "P-36-13" page 120 "P-38-7" page 2; 3 1352 2,343,092.55 Annex 5 1,687,108.95 655,983.60 13,119.67 "P-36-9" page 6 "P-38-9" page 807; 3 1427 1,046,2 16.94 Annex 5 224,463 .30 821,753.64 16,4 35.07 "P-36- 11" page 1119 & 1120 "P-38-9" page 808; 3 1467 311,342.41 Annex 5 175,136.59 136,205.82 2,724. 12 "P-36- 1 1" page 1124 "P-38-7" page 2; 31564 2, 150,455 .99 Annex 5 1,547,840.40 602,615.59 12,052.3 1 "P-36-9" page 6 "P-38-9" pages 823 , 923, 924, 926 to 928, 31801 Annex 5 1006, 1008 & 115,112.22 57,719.57 57,392 .65 1,147.85 1009; "P-36-1 1" page 1475 (not traced to ap_ 3 18 4 5 1,078,904.00 A nnex 5 - 38-1 0" oaae 8 7) 1,078,904.00 21,578.08 "P-38-11" page 125; 31617 5,325.48 Annex 5 258 . 12 5,067.36 101.35 "P-36-13" page 130 Subtotal P13, 763,991.95 P5, 931 , 181.54 P7, 832 810.41 P156,656.20 "P-39- 1" page 1 & "P-39-8" page 8962 r 819,930.00 Annex 14 , 60,350.00 1• "P-36-2"' page 1 p 759,580.00 p 15,191.60 & "P-36-1 1" page 173 (not traced to "P- 9074 122,082.00 Annex 14 - 39-3" vaae 8) 122,082.00 2,441.64 "P-39 -3" pages 37,44 & 45; 9277 Annex 14 25,300.00 2 1,100.00 "P-36-4" page 4,200.00 84.00 537 "P-39-3" page 4 7 &48; 9363 Annex 14 917.00 60,650.00 14,800.00 "P-36-4" page 45,850.00 560 "P-39-3" pages 198, 199, 204 to 10366 92,960.00 Annex 14 206; 659.20 60,000.00 32 ,960.00 "P-36-4" page 1024 & 1026 10371 2 1 000 .00 Annex 14 4,400 .00 "P-39 -3" page 16 600.00 332.00

AMENDED DECISION CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal Revenue x---------------------------------------------------------------------------------------------------------x 194; "P-36-4" page 1029 "P-39-3" pages 201 to 203; 10410 44 ,160.00 Annex 14 9,000.00 35,160.00 703.20 "P-36-4" page 1066 Subtotal p 1,186,082.00 p 169,650.00 t-1,016, 432.00 p 20,328.64 Total P14,950,073.95 P6,100,831.54 P8,849,242.41 P176,984.84 Consequently, only P1,230,401,742.63 of the income payments reported by the !CPA as having been traced were verified by the Court as forming part of the income declared in petitioner's AITR for CY 2020, with corresponding CWTs of P25,762,974.39, as follows : Income payment CWT Income payment traced per !CPA p 1 ,239,250, 985.04 p 25,939 ,9 59.23 findings Less: Not traced to income per the 8 ,849,242.41 176,984.84 Court's further verification Income payments traced as P1,230,401, 742.63 P25, 762,974.39 verified In view of the foregoing, the Court finds that, out of the substantiated CWTs of P30,208,502.00, only the amount of P25,762,974.39 satisfies the third requisite for the refund of unutilized CWTs, i.e., that the income payments upon which the said CWTs were withheld were declared as part of petitioner's gross income in its AITR for CY 2020. WHEREFORE, premises considered, petitioner's Motion for Reconsideration (Re: Decision dated 22, [sic] January 2026) is PARTIALLY GRANTED. Accordingly, the dispositive portion of the Decision dated January 22, 2026, is hereby AMENDED to read as follows: "WHEREFORE, 1n light of the foregoing considerations, the present Petition for Review is PARTIALLY GRANTED. Respondent is hereby ORDERED TO REFUND petitioner the amount of P25,762,974.39 , representing the latter's unutilized creditable withholding taxes for calendar year 2020. SO ORDERED."

AMENDED DECISION CTA Case No . 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal Revenue x---------------------------------------------------------------------------------------------------------x SO ORDERED. ~~~ LANEE S. CUI-DAVID Associate Justice !CONCUR: ~/~ BACORRO-VILLENA ATTESTATION I attest that the conclusions in the above Amended Decision were reached in consultation before the case was assigned to the writer of the opinion of the Court's Division. \ ~ A. BACORRO-VILLENA iate Justice ~~ Chairperson

AMENDED DECISION CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal Revenue x---------------------------------------------------------------------------------------------------------x CERTIFICATION Pursuant to Article VIII, Section 13 of the Constitution, and the Special First Division Acting Chairperson's Attestation, it is hereby certified that the conclusions in the above Amended Decision were reached in consultation before the case was assigned to the writer of the opinion of the Court's Division. ~.~ t - -. MA. BELEN M. RINGPIS-LIBAN Presiding Justice