June 20, 2019
ITAD BIR RULING NO. 018-19
Sections 109 (K), 106 (A) (2) (b) and 108 (B) (3), Tax Code, as amended;
Articles 1 & 23, Vienna Convention
Her Britannic Majesty's Embassy
120 Upper McKinley Road, McKinley Hill
1634 Taguig City, Metro Manila
Attention: AAA
_______________
Gentlemen :
This refers to your Note No. 19-090 dated 01 May 2019 requesting for the issuance of a confirmatory ruling on the exemption of Her Britannic Majesty's Embassy from the payment of taxes in respect of its premises pursuant to Article 23 of the Vienna Convention on Diplomatic Relations of 1961 (Vienna Convention).
In reply, please be informed that transactions involving real properties are generally subject to taxes under various provisions of the National Internal Revenue Code (Tax Code) of 1997, as amended, depending on the type of transaction.
However, as regards income tax, Section 32 (B) (5) of the Tax Code of 1997, as amended, states that "x x x exempt from income tax are income of any kind to the extent required by any treaty obligation binding upon the Government of the Republic of the Philippines."
With...
