\C REPUBLIC OF THE PHILIPPINES \/ DEPARTMENT OF FINANCE : BUREAU OF INTERNAL REVENUE __ [Article 10, Philippines-Tapan tax treaty, as amended BIR Ruling No. ITAD-_097=14 Date: June 30 201 SGV & Co. 6760 Ayala Avenue 1226 Makati City Attention: Carolina A. Racelis Principal, Tax Services Gentlemen: ‘This refers to your Tax Treaty Relief Application (“TTRA”) filed on September 24, 2013, on behalf of JFE Steel Corporation (“JFE”), requesting confirmation that-dividends paid by Philippine Sinter Corporation (“PSC”) to JE are subject to a preferential tax rate of 10 percent pursuant to Article 10 of the amended Convention between the Republic of the Philippines and Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (“Philippines-Japan tax treaty, as amended”). It is represented that JFE, with address at Hibiya Kokusai Building, 2-3, Uchisaiwaicho 2-chome, Chiyoda-ku, Tokyo, Japan, is a resident of Japan per the Resident Certificate issued on July 19, 2013 by the District Director of Kojimachi Tax Office; that it was licensed to established its representative office in the Philippines (“JFE-Philippine Rep- Office”) per Certificate of Corporate Filing/Information issued by the Securities and Exchange Commission dated September 3, 2013; that per Certification dated September 10, 2013 issued by JFE-Philippine Rep-Office, it has no relation, participation or intervention, whatsoever, with respect to the declaration of dividends by PSC. The said dividends to be acquired by JFE is independent from its JFE-Philippine Rep-Office and that JFE- Philippine Rep-Office has no participation or intervention, directly or indirectly, in the execution and consummation of declaration of dividends, the ownership and subscription to the subject shares of stock are solely between PSC and JEE; and that, on the other hand, PSC is a corporation organized and existing under the laws of the Philippines with business address at 23° Floor, 6788 Ayala Avenue, Oledan Square, Makati City. tis further represented, that on June 3, 2013, PSC declared cash dividends to all its stockholders of record as of June 3, 2013 in the aggregate amount of Three Hundred Million Pesos (Php300,000,000.00), payable on or before September 30, 2013; that based on the Corporate Secretary’s Certificate issued by PSC dated August 27, 2013, JFE owns 99,9999% of PSC’s total issued and outstanding shares and has held and owned said shares since PSC’s incorporation in 1974; and that, based on the Bank Certification issued by Rizal Commercial JIFE Steel Corporation - Dividends Page 1 of 6 UR Ruling NO.ITAD- 9. 59 025234