August 20, 2019

DA ITAD BIR RULING NO. 032-19

Principle of Reciprocity;
BIR Ruling No. ITAD-372-12

Embassy of the Russian Federation

1245 Acacia Road, Dasmariñas Village

Makati City

Attention: AAA
__________

Gentlemen :

This refers to Note Nos. 370-n and 369-n both dated 22 July 2019 referred to this Office by the Department of Finance (DOF) and the Department of Foreign Affairs (DFA), requesting for exemption from payment of value-added tax (VAT) and ad valorem tax on the local purchase of two (2) motor vehicles for the official use of the Embassy of the Russian Federation, specifically described as follows:

Make:

2019 Toyota Fortuner 2.4 4x2 G DSL A/T

2019 Toyota Camry 2.5 V A/T

Motor/Engine No.:

2GD4675649

2AR2167134

Frame/Chassis No.:

MHFJB8GS9K1570293

MR2BF3HK5K4003642

Color:

Phantom Brown Metallic

Platinum White Pearl

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 goods or services; x x x." (Underscoring supplied)

Thus, the tax exemption privilege of an Embassy and its diplomatic agents...

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