Tax Exempt Granted to Shell Gas Philippines, Inc.

May 20, 1981 BIR RULING NO. 084-81 222-00 000-00 084-81 Shell Gas Philippines, Inc. 1330 Roxas Boulevard M a n i l a Attention: Mr . V . K . Esteban Treasury Manager Gentlemen : This refers to your letter dated March 17, 1981 requesting confirmation, that Shell Gas Philippines, Inc. is exempt from all national internal revenue taxes directly payable by it, including documentary stamp taxes, except income tax. It is represented that Shell Gas Philippines, Inc. is a domestic corporation primarily organized for the purpose of engaging in the production, manufacture and exportation of liquefied petroleum gas; that it is registered with the Export Processing Zone Authority as a Zone Export Enterprise as per EPZA letter dated September 10, 1980; that it is registered with the Board of Investments on a preferred pioneer status under Republic Act No. 6135 effective June 3, 1980, under Certificate of Registration No. 80-1164. cdtech In reply, I have the honor to inform you that our answer is in the affirmative. As a registered export producer on a pioneer status, you shall be entitled to the incentives set forth in Section 8(a) of R.A. 5186, which grants exemption from all taxes, on a graduated scale, under the National Internal Revenue Code, as amended, except income tax. (Sec. 7, R.A. No. 6135; Sec. 2, Rule VIII, Revised Rules and Regulations Implementing R.A. No. 6135) It may be stated that the exemption privilege of pioneer enterprises from all national internal revenue taxes shall cover only such direct tax liabilities as may be imposed in connection with the operation of the registered pioneer project and shall exclude such taxes as may be transferred or passed on to the registered enterprise either by business practice or mere contractual arrangement. (Sec. 6, Rule XIII, Rules and Regulations to Implement the Intents and Provisions of R.A. No. 5186, as amended in relation to Section 2, Rule VIII of the Revised Rules and Regulations to Implement the Intent and Provisions of R.A. No. 6135). Very truly yours, RUBEN B. ANCHETA Acting Commissioner