BIR Ruling

March 23, 1970 The Shell Refining Company (Phil.) Inc. 1330 Roxas Boulevard Manila Gentlemen : With reference to your letter dated July 14, 1969, requesting that any tax credit due The Shell Company of the Philippines Ltd. be applied instead against your outstanding and/or future internal revenue tax liability, I have the honor to inform you that your request cannot be granted by this Office on the ground that the specific tax sought to be refunded and/or credited was paid by The Shell Company and, therefore, the proper entity entitled to the refund. Please be informed that future claims of The Shell Company of the Philippines for tax credit of the specific taxes paid on the petroleum products sold to the Armed Forces of the Philippines, thru Arabay, Inc. will no longer be entertained by this Office. Inasmuch as you are the taxpayer, the petroleum products should accordingly, be sold directly by you to the tax-exempt entity. Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue