April 5, 2019
DA ITAD BIR RULING NO. 014-19
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 Nos. 19-039 and 19-040 and dated March 8, 2019 referred to this Office by the Department of Finance and the Department of Foreign Affairs (DFA), requesting for the exemption from the payment of value-added (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: HTcADC
MAKE | YEAR | COLOR | CHASSIS NO. | ENGINE NO. |
Toyota Fortuner 2.7L 4x2 G Gas AT-X1-005 | 2018 | Silver Metallic | MHFJX8GS8J0607257 | 2TRA495913 |
Toyota Fortuner 2.7L 4x2 G Gas AT-X1-005 | 2018 | Attitude Black Mica | MHFJX8GSXJ0607230 | 2TRA493072 |
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...
