March 16, 2018

DA ITAD BIR RULING NO. 011-18

Principle of Reciprocity;
BIR Ruling No. ITAD-301-11

Embassy of Canada

Levels 6-8, Tower 2, RCBC Plaza Bldg.

Ayala Avenue, Makati City

Gentlemen :

This has reference to your Note No. 18-027 dated February 14, 2018 referred to this Office by the Department of Finance and the Department of Foreign Affairs, requesting for the exemption from the payment of value-added tax (VAT) and ad valorem taxes on the local purchase of a motor vehicle for the official use of the Embassy of Canada, specifically described as follows: aDSIHc

Type of Use:

Official

Make:

Toyota HiAce GL Grandia 3.0 DSL A/T

Model Year:

2018

Color:

Silver Metallic

Frame Number:

JTFRT13P0J8023253

Engine Number:

1KD2787881

In reply, please be informed that Article 34 of the Vienna Convention on Diplomatic Relations reads:

"ARTICLE 34

A diplomatic agent shall be exempt from all dues and taxes, personal or real, national, regional or municipal, except:

(a) indirect taxes of a kind which are normally incorporated in the price of the goods and services;

xxx xxx xxx"

Thus, the tax exemption privilege of an Embassy and its diplomatic agents does not include exemption from VAT on its local purchases of...

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