Corporate loan to Agri Exim Global Philippines, Inc.

As part of the LafargeHolcim’s business divestment from the Philippines involving its Philippine subsidiaries, we were engaged by LafargeHolcim to determine the most tax efficient way to repatriate its capital investment and accumulated profits. We are advising the client on the tax implications of its intended divestment on various options such as the (1) equity restructuring of its Philippine subsidiaries, (2) declaration of dividends, and (3) redemption of shareholdings. The project also involves seeking of various tax treaty reliefs before the Bureau of Internal Revenue for exemptions on or application of preferential rates for income taxes based on the tax treaty.