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May 31, 1999ITAD RULING NO. 007-99Sec. 107 Sec. 109 000-00Romulo, Mabanta, Buenaventura Sayoc & De Los Angeles Law Offices30th Floor, Citibank Tower, Citibank Plaza,8741 Paseo de Roxas, Makati CityAttention: Atty. Edmundo P. GuevarraandAtty. Jayson L. FernandezGentlemen :This refers to your letter dated 14 August 1998 requesting in effect for a confirmation of your opinion that the ground equipment, spare parts, engines, fuel, lubricants and other consumable technical supplies which are brought into the Philippines by the United Parcel Service Co. (UPSCo) exclusively for the servicing, maintenance, use or repair of its aircraft are exempt from all taxes and duties imposed under the National Internal Revenue Code of 1997 and the Tariff and Customs Code pursuant to Article 9 of the RP-US Air Transport Agreement dated September 16, 1982, as amended, and Article 24 of the Convention of International Civil Aviation which was signed at Chicago on December 7, 1944. digestIt is represented that UPSCo is a foreign corporation organized and existing under the laws of the State of Delaware, U.S.A. with a branch office in...