BIR Ruling

January 28, 1977 Land Bank of the Philippines 6th Flr. B.F. Condominium Bldg. Intramuros, Manila Attention: Dr . Juan T . Reyes, Jr . Senior Vice-President Gentlemen : This refers to your letter dated December 8, 1976 requesting opinion on the propriety of the action taken by the Land Transportation Commission (LTC) in imposing against the Land Bank of the Philippines the payment of registration fees and energy tax for the registration of the latter's motor vehicles. It is your contention that the Land Bank is exempt from the payment of the registration fee for motor vehicles and the energy or ad valorem tax on account of the provisions of Section 98 of R.A. No. 3844, as amended by Section 22 of P.D. No. 251 and Section 1 of P.D. No. 338, which state: "The Land Bank shall be exempt from all national, provincial, municipal and city taxes and assessments now enforced or hereinafter established. "The exemption authorized in the preceding Section shall apply to all property of the Bank, to the resources, receipts, expenditures, profits and income of the Bank, as well as related to the conduct of the business of the Bank, Provided , however , that said exemptions shall apply only to such taxes and assessments for which the Bank itself would otherwise be liable and shall not apply to taxes or assessments payable by persons or other entities doing business with the Bank." In reply, I have the honor to inform you, that inasmuch as all the property of the Land Bank under its charter, are exempt from all taxes, it is the opinion of this Office that the motor vehicles owned by the Land Bank are exempt from the payment of the energy tax. cdt As regards your request to be exempt from the payment of registration fees under the provisions of R.A. No. 4136, as amended, it is suggested that the matter be taken up with the Commissioner of the Land Transportation Commission, the agency charged with the enforcement of said law. Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-1456-040-3 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."