BIR Ruling No. 352-2017

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No. 3522017

CERTIFICATE OF TAX EXEMPTION issued to

PNOC Bldg. VI. Energy Center Rizal Drive, Bonifacio Global City.Fort Bonifacio. Taguig City 1630 PHILIPPINE NATIONAL OIL COMPANY TIN:

PHILIPPINE NATIONAL OIL COMPANY in favor of: This certifies that the Deeds of Donation dated March 10. 2017 executed by

Name of Donee Philippine Navy TIN 2335. Roxas Boulevard. Malate. Headquarters Philippine Navy Manila 1004 Address

covering the following vessels/tankers described below. to wit:

Gross Tonnage Vessel's Name Construction Net Tonnage Engine Make Year Built Breadth Length Depth Hull Steel/Double Hull Emilio Jacinto Yanmar Diese 83.23 meters 13.80 meters 7.28 meters MTPNOO 2526 MT 1288 MT Enginc 2007 Double-Hulled 95.09 meters Lapu-Lapu 15.60 meters 2.963.00 MT 1.425.00 MT MT PNOC 7.40 meters Daihatsu 2007 Steel/Double Hull Dr.Jose P.Rizal Wusi Sida Diesel 93.01 meters 13.50 meters 6.35 meters 2230 MT 1190 MT Engine 2003 MT

being gifts in favor of the Philippine Navy a naval service branch of the Armed Forces of the Philippines. are exempt from the payment of the donor's tax pursuant to Section 101 (A)(2) of the Tax Code of 1997. as amended.

stamp tax prescribed under Section 196 of the Tax Code of 1997. as amended. However. the acknowledgements of the Deeds of Donation before a notary public are subject to the documentary stamp tax of P15.00 imposed under Section 188 of the same Code. Accordingly, the Deeds of Donation are likewise not subject to the documentary

that the facts are different, then this Certificate shall be considered null and void. documents as represented and submitted. However, if upon investigation, the BIR ascertains This Certificate of Tax Exemption is being issued on the basis of the facts and

Issued this day of AUG 08 2017

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K-I-JAC Commissioner of Internal Revenue CAESAR R.DULAY t 008407