BIR Ruling

November 29, 1972 Asian Institute of Management Eugenio Lopez Foundation P. O. Box 898 Makati, Rizal Attention: Mr . Jacques V . Schanabel Director of Administrative Services Gentlemen : This refers to your letter dated September 20, 1972 requesting exemption from the payment of the tax clearance fees of those nationals coming under any of the following capacities: 1. to enrol as full-time students in its two-year Master of Business Management Program; 2. to participate in any of its conferences, workshops or seminars on advances management practices and/or education. In reply, I have the honor to inform you that the aforesaid persons cannot be granted exemption from the payment of the tax clearance fees for lack of legal basis. The exemptions provided for in Section 343 of the Tax Code cannot be construed as including the aforesaid persons. In other words, they are not included among those persons exempt by law from securing tax clearance certificates nor are they included among those exempt from the payment of documentary and science stamp taxes in securing tax clearance certificates. However, those foreign nationals who have come merely as scholars, trainees, participants or students of the Asian Institute of Management, whose stay in the Philippines do not exceed fifty nine days may be exempted from securing tax clearance certificates. (Sec. 225 in rel. to Sec. 343 of the Tax Code; Rev. Regs. No. V-32, as amended by Rev. Regs. No. V-49, Dept. of Finance) cdta Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue