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October 14, 2019ITAD BIR RULING NO. 033-19Section 101 (B) (1); National Internal Revenue Code of 1997,as amendedDepartment of Environment and Natural ResourcesVisayas Avenue, Diliman1100 Quezon CityAttention: AAA_______________Gentlemen :This refers to your letter dated November 24, 2017 requesting confirmation that light-emitting diode ("LED") streetlights and household solar power system (collectively referred to as "items") donated by the Government of the People's Republic of China, through its National Development and Reform Commission ("NDRC"), to the Department of Environment and Natural Resources ("DENR") are exempt from donor's tax under Section 101 (B) (1) of the National Internal Revenue Code of 1997 ("Tax Code"), as amended. SDHTECOn November 15, 2017, NDRC and DENR entered into a Memorandum of Understanding Concerning the Provision of Goods for Addressing Climate Change ("MOU") where NDRC agreed to provide 20 million yuan worth of LED streetlights and household solar power system to DENR to enhance the Philippines' domestic capacity in combatting climate change. NDRC agreed to provide to the local government beneficiaries, through DENR, the following: Local Government UnitNumber of BeneficiariesItemsSpecificationsQuantityProvince of Antique100 barangays...