BIR Ruling

August 3, 1967 Mr. Primitivo Lovina President, Philippine Veterans Bank Manila S i r : This refers to your request for reconsideration of our ruling dated March 5, 1965. LexLib In reply thereto, I have the honor to inform you that this Office finds no cogent reason to reverse its previous ruling denying the request of the Philippine Veterans Bank for exemption from the payment of income tax. While it may admitted that the Philippine Veterans Bank is a corporation organized for the rehabilitation of veterans, an exempt organization within the purview of Section 27(e) of the Tax Code, said law, however, imposes as a limitation to income tax exemption the fact that no part of the net income of said corporation must inure to the benefit of any private stockholder or individual. As can be gleaned from Section 22(b) of Republic Act No. 3518, private stockholders of the Philippine Veterans Bank will reap benefits by way of dividends. While your suggestions are well-meant and for a laudable purpose, such a purpose, however, is not sufficient basis for exemption. The weight of authorities is to the effect that the who claims an exemption must be able to justify his claim by clearest grant of organic or statute law. An exemption from the common burden cannot be permitted upon vague implication. (Asiatic Petroleum Co. v. Llanes, 49 Phil. 466, 467). Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue