BIR Ruling

January 18, 1972 St. John Trading 156 Aurora Blvd. San Juan, Rizal Gentlemen : This refers to your letter dated January 10, 1972 requesting information as to whether or not the receipts you derive from the Asian Development Bank in connection with your contract with said Bank for the clearing with customs and the delivery and installation of imported kitchen equipments in the building of a Bank now under construction is subject to the 3% contractor's tax. In reply, I have the honor to inform you that the 3% contractor's tax is not a liability of the Bank but your direct and personal liability. Such being the case, your inquiry is answered in the affirmative. The exemption of the Bank can be availed of only by it and only with respect to taxes on which it would otherwise be directly and personally liable. cdta Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue