Please note that in terms of offshore portion from NBCC2 project, it was an idea of the management of
SC to declare/include such income to the Thai tax authorities in Thailand by including such amount
even though all of offshore procurement portion is done outside Thailand. To confirm its position
adopted, in the last couple years, SC, by the designated person for NBCC2 (Thai person), had verbally
confirmed the said practical CIT filing for the above all projects (agent, offshore and onshore) with the
tax officer in-charge and tax officer in-charge had verbally agreed with the said practical CIT filing
adopted by SC. However, we have not obtained such nature, agreement or information in details about
offshore procurement.