BIR Ruling

June 8, 1977 Philippine Veterans Investment Development Corporations 2nd & 3rd Floor, Dao 1 Salcedo St. Legaspi Village, Makati Rizal Attention: Mr . Teodorico P . Almuete President Gentlemen : This refers to your letter dated May 25, 1977 requesting exemption from the payment of tobacco inspection fee on the removal of tobacco from the redrying plant of the Corporation under the provisions of the Presidential Decree No. 243, as amended. It appears that the Philippine Veterans Investment Development Corporation is a body corporate and politic created and organized under PD 243; that among the purposes for which it was created is to engage in any commercial, industrial, mining, and agricultural and other enterprises which may be necessary or contributory to the economic development of the country, or important in the public interest or which will promote the well-being of the veterans and retirees of the Armed Forces of the Philippines; that the corporation has since 1976 leased from the Ilocandia Tobacco Processors, Inc. (ITPI) The Tobacco Redrying Plant in Currimao, Ilocos Norte; that the movement of tobacco from trading centers to the redrying plant and then to the owners warehouses is an essential element in its operation; and that the inspection fees for all tobacco leaving the trading centers and destined to the corporations' redrying plant have been paid for at the source. aisadc In reply, I have the honor to inform you that under the foregoing circumstances, the removal of tobacco from the redrying plant of the corporation is exempt from payment of the inspection fee prescribed in Section 302 of the Tax Code pursuant to Section 5 of Presidential Decree No. 243 as amended by P.D. 353 and P.D. 918, pertinent portion of which provides: "Section 5. . . . "xxx xxx xxx "The corporation shall be exempt from the payment of any and all taxes, duties, charges, fees and assessments of whatever nature and description imposed by any authority, whether national or local." (Emphasis ours) Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-P4519-F2828-A-8 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."