Offshore Branch Authorized by the Central Bank Subject to 10% Overseas Communications Tax

January 17, 1984 BIR RULING NO. 006-84 290-A-000-00-006-84 Gentlemen : This refers to your letter dated April 30, 1983 requesting exemption from the 10% overseas communications tax prescribed under Section 290-A of the Tax Code. It is represented that you are authorized by the Central Bank to operate as an Offshore Branch in the Philippines effective May 2. In reply, please be informed that Section 290-A of the Tax Code, as amended by Presidential Decree No. 1457, explicitly limits the exemption from the payment of the 10% overseas communications tax to only four (4) entities, namely: 1. Government, 2. Diplomatic Services, 3. International Organizations, and 4. News Services. It appearing that Offshore Branch authorized by the Central Bank to operate in the Philippines is not among those enumerated, it is regretted that your request for exemption from the said tax cannot be granted for lack of legal basis. Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner