June 20, 2019
ITAD BIR RULING NO. 019-19
Section 28 (A) (a), National Internal Revenue Code of 1997,
as amended
KLM Royal Dutch Airlines
39th Floor, Yuchengco Tower, RCBC Plaza
Ayala Avenue corner Sen. Gil Puyat Avenue
1200 Makati City
Attention: AAA
__________
Gentlemen :
This refers to your letter dated January 11, 2019 requesting confirmation that Koninklijke Luchtvaart Maatschappij N.V. Royal Dutch Airlines ("KLM Airlines") continues to be exempt from income tax on its Gross Philippine Billings on the basis of reciprocity pursuant to Section 28 (A) (3) (a), National Internal Revenue Code of 1997 ("Tax Code"), as amended. HTcADC
As represented, KLM Airlines is an international air carrier organized and existing under the laws of the Netherlands. It was issued a license to establish a branch office in the Philippines by the Securities and Exchange Commission on August 8, 1955. According to Chapter III, Article 19 of the 1969 Corporation Tax Act of the Netherlands, as certified by the Competent Tax Authority, income, profits and gains derived by foreign shipping and air transport companies from the operation of ships or aircraft in international traffic, i.e.,...