January 28, 2019
DA ITAD BIR RULING NO. 002-19
Section 106 (A) (2) (b), NIRC of 1997, as amended; Section 9, Revenue Regulations No. 25-2003;
Section 34, Article IX, ADB Headquarters Agreement; BIR Ruling No. ITAD-011-14
Asian Development Bank
6 ADB Avenue, Mandaluyong City
Attention: AAA
__________
Gentlemen :
This refers to your letters dated December 18, 2018 indorsed to this Office by the Department of Finance and the Department of Foreign Affairs, requesting exemption from value-added (VAT) and ad valorem taxes on the local purchase of two (2) motor vehicles for the official use of the Logistics Management Unit of the Asian Development Bank (ADB), specifically described as follows:
MAKE | MODEL YEAR | COLOR | CHASSIS NO. | ENGINE NO. |
Toyota Camry 2.5V A/T | 2019 | Thermalyte | MR2BF3HK4J4000391 | 2AR2083460 |
Toyota Camry 2.5V A/T | 2019 | Thermalyte | MR2BF3HK2J4000342 | 2AR2080235 |
In reply, please be informed that Section 106 (A) (2) (b) of the National Internal Revenue Code (NIRC) of 1997, as amended by Republic Act No. 10963, otherwise known as the Tax Reform for Acceleration and Inclusion (TRAIN) Act, provides, viz.:
"SEC. 106. Value-Added Tax on Sale of Goods or Properties. —
(A) Rate and Base of Tax. — There shall be levied, assessed and collected on...
