Exemption from Specific Tax — Oil Products

February 5, 1980 BIR RULING NO. 011-80 Intermodal Shipping Agencies, Inc. Dolmar Bldg., 1136 - 1138 UN Avenue Paco, Manila Attention: Mr . Manuel H . Puey Vice President/Treasurer Gentlemen : This refers to your letters dated March 12, 1979 and April 11, 1979 requesting that your company be exempted from the payment of specific tax due on oil products purchased for the consumption of the vessels of your principals plying international waters. It is represented that you are involved in servicing vessels of local and foreign/principal owners; that these vessels are of Philippine and Liberian registries plying Japan, Philippines, Indonesia and HongKong routes; that as part of the service, you supply the diesel and fuel oil requirements of such vessels; and that you advance the cost of said oil products but you are later on reimbursed by your principals after receipt of the billing statement. In reply thereto, please be informed that in an amendment introduced by P.D. No. 1359 to Section 134 of the Tax Code of 1977, the second paragraph of said section now provides: "However, petroleum products sold to an international carrier for its use or consumption outside of the Philippines shall not be subject to specific tax, Provided ,that the country of said carrier exempts from tax petroleum products sold to Philippines carriers." Since Liberia grants reciprocal tax exemption privileges to Philippine registered international carriers we confirm that your purchases of petroleum products for the consumption of the vessels belonging to your principals, which vessels are of Philippine and Liberian registries and which are engaged in international voyages are exempt from specific taxes. cdta Very truly yours, RUBEN B. ANCHETA Acting Commissioner