BIR Ruling

October 27, 1969 Mindanao Development Authority 3rd Floor, Aldevinco Bldg. Claro M. Recto Ave. Davao City Attention: Mr . Luis A . Lopez Chairman Gentlemen : This refers to your 2nd Indorsement dated July 15, 1969 requesting reconsideration of the ruling contained in our letter dated May 19, 1969 subjecting the Mindeva Refrigeration Industries, Inc. (MRII) to the basic and additional residence taxes. As represented, the Mindeva Refrigeration Industries, Inc., organized in April, 1967 is a subsidiary corporation of the Mindanao Development Authority which is exempt from all taxes incidental to its operation, pursuant to Sec. 12 of Rep. Act 3034; that the majority or 99.99% of the stocks of the MRII are subscribed abd owned by the said Authority; and that the Secretary of Finance has held that for Mindanao Development Authority subsidiaries to be entitled to tax exemption, majority of the stocks must be owned by the Authority. In reply thereto, I have the honor to inform you that under the foregoing representation, Mindeva Refrigeration Industries, Inc., is exempt from the payment of the basic and additional residence taxes subject to the conditions and limitations prescribed in Section 12 of R.A. No. 3034. This supersedes our previous ruling above-stated. cdll Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue