BIR Ruling

August 5, 1969 Mr. Zosimo Q. Pizarro Associate Executive Officer The International Rice Research Institute Los Baos, Laguna S i r : This refers to your letter dated May 21, 1969, requesting reconsideration of the ruling of this Office dated March 18, 1969 holding that personnel of the I.R.R.I. are not exempt from the payment of documentary and science stamp taxes on their application for tax clearance certificates. In reply, I have the honor to inform you that your request is hereby granted subject, however, to the condition that the exemption will apply only to Institute personnel who are on official or Institute's business at Institute's expense as certified to by the Institute's Executive Officer, inasmuch as payment of documentary and science stamp taxes if made by the Institute constitutes a direct liability which cannot be imposed on the latter since it enjoys an all-embracing tax exemption under Republic Act No. 2707. (Opinion No. 109, series of 1963, Secretary of Justice) Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue