b. In reviewing the TPI auditor’s reports for the periods prior to the date of issuance of the TRD ruling, TPI’s position was that there would be no withholding tax due in accordance with Section 4 of Royal Decree 340 as the creditors would be receiving income from the transferring of assets. [See Notes to Interim Financial Statements of Thai Petrochemical Industry Public Company Limited and Subsidiaries for March 31, 2003 attached as Appendix 13