BIR Ruling

June 10, 1976 Southeast Asian Regional Center for Graduate Study and Research in Agriculture (SEARCA) College, Laguna 3720, Philippines Attention: Mr . J. D. Drilon, Jr . Director Gentlemen : This refers to your request, in behalf of your personnel, for exemption from the payment of documentary and science stamp taxes on their application for tax clearance certificates whenever they travel officially for the Center and at the Center's expense, pursuant to the provision of Republic Act No. 6450. Pertinent provision of Section 1 Republic Act No. 6450 under which exemption is sought reads as follows: "Section 1. The provision of existing laws to the contrary notwithstanding, the Southeast Asian Regional Center for Graduate Study and Research in Agriculture . xxx xxx xxx shall be exempt from the payment of compensating taxes, duties and fees, provided under existing laws and regulations . This exemption shall extend to goods imported or exported on a non-commercial basis by the Regional Center . . . Provided, That such exemption shall not apply to articles which are subject to specific tax under Title IV of the National Internal Revenue Code and articles subject to percentage tax under Section 184 in relation to Section 190 of the same Code." (Emphasis supplied) aisa dc It is clear from the above-quoted provision that the tax exemption is a privilege granted to the Center itself and not its personnel. Moreover, the exemption does not include documentary and science stamp taxes. Such being the case, it is regretted that your request cannot be granted for lack of legal basis. 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."