BIR Ruling No. 571-2020

BUREAU OF INTERNAL REVENUE REPUBLIC OI THF PHILIPPINES DEPARTMENT OF FINANCE Quezon City

X

SN:MSIA-0571-202

CERTIFICATION

delivery of the collateral appurtenant thereto, are not subject to capital gains tax (CGT), stock particularly the Master Securities Lending Agreement with MSLA Ref. No. January i6, 2019, the original of which is attached hereto and made an integral part hereof, the borrowing and lending of securities within the borrowing period not exceeding two years, and the transaction tax and documentary stamp tax (DST). THIS IS TO CERTIFY that, on the basis of the representations and documents submitted, executed on

The said MSLA is executed by and between:

City, as the LENDER, represented herein by Benito B.H. Ang, address at Units 1204-1205 Tower One & Exchange Plaza, Ayala Avenue, Makati ASTRA SECURITIES CORPORATION (TIN: with business

-and-

City, as the BORROWER, represented herein by Barnaby Barrett T. Ang. ASTRA SECURITIES CORPORATION (TIN: address at Units 1204-1205 Tower One & Exchange Plaza, Ayala Avenue, Makati with business

to the penaities provided for under Sections 248 and 249 of the same Code, as implemented by the No. 001-2008. Violation of this requirement shall subject the transaction to taxes imposed under Sections~24(C25A3,28A7c,28B5c127(Aas applicableand Section175of 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 said regulations. The Lender/Agent and Borrower/Agent are required to submit bi-annual summary reports of

245 of the National Internal Revenue Code of 1997, as amended, and in RR No. 10-2006, as amended. for misrepresentation or for violations of the conditional requirements set forth in Sections 244 and This Certification shall be valid unless sooner suspended, cancelled, or revoked by this Office

OCI 0 6,2020 IN TESTIMONY WHEREOF, I have hereunto set my hand, this day of

Maesamre

Registration Fee of FIVE THOUSAND PESOS (P5,000.00) was paid on March 27, 2019 under BIR e-Payment Transaction No. 198052338. Commissioner of Internal Reven CAESAR R.DULAY 036841

K-I-LMAT

As a result of the amendments introduced by Republic Act (RA) No. 9243, Section 176 was amended and renumbered to Section

175.