BIR Ruling No. 073-62

May 17, 1962 BIR RULING NO. 073-62 Messrs. Ross, Selph & Carrascoso Attorney-at-Law P. O. Box 781, Manila Gentlemen : This has reference to your letter dated March 3, 1962, requesting opinion to what internal revenue taxes, your client, the Philippines Packing Corporation is liable under the following facts: "Our client, Philippine Packing Corporation, is contemplating engaging in tuna fishing in the high seas and export the fish caught to the United States. The proposed operations call for the chartering of a Japanese vessel for about six (6) months, which would come to the Philippines to unload its catch on to an ocean freighter awaiting at the Philippines port for transshipment to the United States or to a cold storage at the Philippines port pending arrival of an ocean freighter. Thereafter, the vessel would return to the Indian Ocean to fish and later bring again its catch to the Philippines for transshipment abroad." In answer thereto, I have the honor to inform you that, based on the aforequoted facts, your client is exempt from the fixed and percentage taxes prescribed in sections 182(A)(1) and 186 of the Tax Code. It is, however, understood that your client is subject to the income and additional residence taxes. cdll The Above ruling was duly signed by the Acting Commissioner of Internal Revenue on May 17, 1962. Very truly yours, BENEDICTO PADILLA Acting Commissioner of Internal Revenue