January 15, 2020
ITAD BIR RULING NO. 014-20
Section 32 (B) (7) (a), NIRC of 1997; Article 11, Philippines-Japan tax treaty
Consulate General of Japan in Davao
4th Floor, Bormaheco Building
209 J. P. Laurel Avenue, Bajada, Davao City
8000 Davao del Sur
Attention: AAA
_______________
Gentlemen :
This refers to the claim for tax refund of the Consulate General of Japan in Davao, representing the final withholding taxes quarterly deducted from its current accounts with China Banking Corporation (Chinabank) Davao-Recto Branch in 2017 and 2018, which was referred by Revenue District Office No. 51-Pasay City to the International Tax Affairs Division of this Bureau for the issuance of a BIR Ruling confirming the Consulate General's entitlement to income tax exemption.
In reply thereto, please be informed that Sec. 32 (B) (7) (a) of the National Internal Revenue Code (NIRC) of 1997, as amended provides, viz.: AcICHD
"Sec. 32. Gross Income. — x x x
(B) Exclusions from Gross Income. — The following items shall not be included in gross income and shall be exempt from taxation under this Title: x x x
(7) Miscellaneous Items. —
(a) Income Derived...
