January 9, 2020
ITAD BIR RULING NO. 008-20
Section 32 (B) (5), NIRC of 1997, as amended; Section 56 (2),
ADB Charter; Article XII, Section 45, Headquarters Agreement
Philkoie International, Inc.
Unit 1701, 17th Floor, The Orient Square Building
F. Ortigas Jr. Road, Ortigas Center, San Antonio
1605 Pasig City
Attention: AAA
_______________
Gentlemen :
This refers to your letter dated 29 March 2019 requesting an opinion on whether or not the salaries and emoluments paid by the Asian Development Bank ("ADB") to its _______________, BBB (hereinafter referred to as "BBB") are exempt from income tax. aDSIHc
Documents submitted show that the ADB issued a Certification confirming that BBB is a ___________ for the joint venture of Nippon Koie Co., Ltd. and Professional Research and Consultancy which the ADB has retained as a consultant for TA-9248 MYA: Rural Productivity and Ecosystems Services Enhanced in Central Dry Zone Forest Reserves-TA Implementation Consultant from 12 November 2018 to 31 January 2022; that with reference to the Agreement Establishing the Asian Development Bank ("ADB Charter"), BBB is an expert performing a mission for ADB and as such, is entitled to...
