October 14, 2019

ITAD BIR RULING NO. 033-19

Section 101 (B) (1); National Internal Revenue Code of 1997,
as amended

Department of Environment and Natural Resources

Visayas Avenue, Diliman

1100 Quezon City

Attention: 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. SDHTEC

On 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 Unit

Number of Beneficiaries

Items

Specifications

Quantity

Province of Antique

100 barangays (approximately...

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