February 6, 2009
VAT RULING NO. 003-09
22; 28; E.O. 226; R.A. 8756; DA-109-2003; DA-167-2005
The Fiduciary and Consulting
International Co. Inc. (RHQ)
No. 504 Anita Building
1300 Quezon Ave. cor. Timog Ave.
Quezon City
Attention: Ms. Armina A. La Torre
Director
Gentlemen :
This refers to your letter dated January 26, 2007 requesting for a ruling regarding the tax exemptions of your company as a Regional Headquarters under the National Internal Revenue Code and the Omnibus Investments Code. EHCDSI
From the documents submitted, it appears that The Fiduciary and Consulting International Company, Inc. (RHQ) ("FIDCO", for brevity) is the regional headquarters ("RHQ") of a multinational company operating in the Asia-Pacific Region and other foreign markets. It was registered with the Securities and Exchange Commission on December 18, 2006 under Company Reg. No. FS200619615.
In reply, please be informed that Section 28 (A) (6) (a) of the Tax Code of 1997, as amended, provides that regional or area headquarters as defined in Section 22 (DD) of the said Code shall not be subject to income tax.
Section 22 (DD) of the Tax Code of 1997, as amended, defines the...
