BIR Ruling

May 2, 1967 Mr. Alberto Suguitan President-Manager, Ilocos Norte Electric Company P.O. Box 9, Laoag City S i r : This has reference to your letter dated March 1, 1967 to the Laoag City Treasurer giving him notice that under the provisions of its new franchise Republic Act No. 3583, the Ilocos Norte Electric Company is no longer subject to the payment of income and real estate tax, a copy of which was furnished this Office. In connection therewith, please be informed that we find your contention in accordance with Section 3 of aforesaid Act, the pertinent portion of which states that: prcd "Effective upon the date the original franchise was granted no other tax upon its capital stock, franchise, right of way, earnings and all other property owned shall be levied or assessed on the herein grantee except the franchise tax of two per centum of the gross earnings mentioned in the said original franchise." However, your exemption from the payment of any other tax except the franchise tax of 2% takes effect only on June 21, 1963, the date when R.A. No. 3583 was approved, and does not retroact as of the date the original franchise was granted. cdta Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue