Exemption Privilege Covers Only Direct Tax Liabilities Imposed on the Operation of Registered Pioneer Project

January 25, 1984 BIR RULING NO. 015-84 222-175-83-015-84 Gentlemen : This refers to your letter dated February 16, 1983 requesting a certification to the effect that you can avail of the incentives granted to you by the Board of Investments in its letter dated February 11, 1983, i.e., the extension of availment of incentives under Section 7(d) and 8(a) of Republic Act No. 5186 at the rate of 100% for the period of one (1) year effective November 1, 1982. In reply, please be informed that said extension finds support under Article 7(14) of Presidential Decree No. 1789, otherwise known as the "The Omnibus Investments Code". Consequently, you are exempt from all taxes, except income tax on all your registered corporate transactions during the period of extension. However, the above exemption privilege shall cover only your direct tax liabilities as may be imposed in connection with the operation of your registered pioneer project and shall exclude such taxes as may be transferred or passed on to you either by business practice or mere contractual arrangement. (Sec. 6, Rule XV, Rules and Regulations implementing P.D. No. 1789). Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner