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June 20, 2019ITAD BIR RULING NO. 019-19Section 28 (A) (a), National Internal Revenue Code of 1997,as amendedKLM Royal Dutch Airlines39th Floor, Yuchengco Tower, RCBC PlazaAyala Avenue corner Sen. Gil Puyat Avenue1200 Makati CityAttention: 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. HTcADCAs 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.,...