March 27, 2019
DA ITAD BIR RULING NO. 010-19
Sections 109 (1) (K), 106 (A) (2) (b), Tax Code of 1997, as amended;
Article XI, PH-Japan TCA; BIR Ruling No. ITAD-010-17
Japan International Cooperation Agency
40th Floor Yuchengco Tower, RCBC Plaza, Ayala Avenue
1227 Makati City
Gentlemen :
This refers to your Note No. 83-19 dated 13 February 2019, referred to this office by the Department of Finance and the Department of Foreign Affairs, requesting exemption from the payment of ad valorem and value-added taxes (VAT) on the local purchase of motor vehicles for the official use of the Japan International Cooperation Agency (JICA), specifically described, as follows: HTcADC
MAKE | MODEL | COLOR | CHASSIS NO. | ENGINE NO. |
Nissan Terra 2.5L 4x4 VL A/T | 2019 | Brilliant Silver | MNTJCND23Z0000437 | YD25797480T |
Nissan Terra 2.5L 4x4 VL A/T | 2019 | Brilliant Silver | MNTJCND23Z0001120 | YD25813521T |
In reply, please be informed of Section 109 (K) of the National Internal Revenue Code (Tax Code) of 1997, as amended, which provides:
"SEC. 109. Exempt Transactions. — (1) Subject to the provisions of Subsection (2) hereof, the following transactions shall be exempt from value-added tax:
xxx xxx xxx
(K) Transactions which are exempt under international agreements to which the Philippines is...
