Annex A

This document is Annex A, a form captioned (per garbled OCR) as a template for information exchange concerning tax rulings issued to a taxpayer. It provides for: a ruling reference; taxpayer identification (TIN or other tax reference number, legal name, address, main business activity, and name of the multinational enterprise); issuance/start/end dates; accounting periods or tax years covered; the type of ruling issued via checkboxes (relating to preferential regime; unilateral advance pricing arrangement (APA)/other transfer pricing (TP) ruling; downward adjustment ruling; permanent establishment (PE) ruling; and what appears to be a conduit ruling); transaction and financial details; a short summary of the issue covered by the ruling (ideally in an OECD official or bilaterally agreed language, completed following the template in Annex B); the reason for exchange with the recipient jurisdiction (e.g., ultimate or immediate parent, related parties, conduit payments, head office of a PE); and details of entities in the recipient jurisdiction. A BIR revenue stamp dated July 30, 2022 with a Records Mgmt Division marking appears on the page. The OCR is heavily garbled, so exact wording and checkbox selections cannot be confirmed.