Salaries and Emoluments of Filipino Employee of UN Food and Agriculture Organization Not Subject to Income Tax

January 9, 1984 BIR RULING NO. 001-84 21-000-00-001-84 M a d a m : This refers to your letter dated May 27, 1983 requesting exemption from income tax on wages received by you from the Food and Agriculture Organization (FAO) of the United Nations for the period from December 1, 1976 to December 31, 1980. In reply thereto, I have the honor to inform you that pursuant to Section 19(b), Article VI of the Convention on the Privileges and Immunities of the Specialized Agencies of the United Nations, officials shall enjoy the same exemption from taxation in respect of the salaries and emoluments paid to them by the specialized agencies and on the same conditions as are enjoyed by the officials of the United Nations. Under Section 18, Article VI of the Convention, only the officials of the specialized agency, e. g., FAO ,whose names are included in the list of tax-exempt officials which shall from time to time be communicated and made known to the Government of member-national are exempt from income tax in respect of the salaries and emoluments received by them from the organization. Accordingly, since the Food and Agriculture Organization of the United Nations is a specialized agency of the United Nations, and your name is included in the list of employed national of the Philippines transmitted by the FAO Hq. Rome, Italy to the Ministry of Foreign Affairs pursuant to said Section 18, Article VI of the Convention, your salaries and emoluments received from the said agency from December 1, 1976 to December 1, 1980 are not subject to income tax. In this connection, please be informed also that a copy of this ruling has been furnished our Regional Office at San Pablo City for its information and appropriate action. Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner