July 22, 2019
DA ITAD BIR RULING NO. 027-19
Principle of Reciprocity;
BIR Ruling No. ITAD-372-12
Embassy of the Russian Federation
1245 Acacia Road, Dasmariñas Village
Makati City
Gentlemen :
This has reference to your Notes No. 302-n and 303-n both dated June 28, 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 two (2) units of motor vehicle for the official use of the Embassy of the Russian Federation, specifically described as follows: HTcADC
MAKE | YEAR | COLOR | FRAME NUMBER | ENGINE NUMBER |
Mazda CX-3 2.0L 2WD AT Pro | 2018 | Eternal Blue | JM7DK2W7AJ1310641 | PE21009573 |
Honda HR-V 1.8 E CVT | 2019 | Taffeta White | MRHRU5830KP020094 | R18ZF3757412 |
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...
