Internal Revenue Tax Exemption on Articles for the Construction of WHO Building, Fixture and Fittings

February 19, 1958 BIR RULING NO. 101-58 Mr. I.C. Fang, M.D. Regional Director World Health Organization Manila S i r : I have the honor to acknowledge receipt of your letter dated February 13, 1958, requesting exemption from the payment of internal revenue taxes on articles purchased in the Philippines and outside the Philippines for the construction of the WHO building and its fixture and fittings. Paragraph 2 of Article III of the Agreement between the Philippine Government and the world Health Organization and on behalf of the United Nations and its specialized agencies concerning office accommodation in Manila provides as follows: "Article III xxx xxx xxx "2. The Organization may import into the country materials and fixtures required for the construction free from all duties and taxes and agrees not to utilize any portion of the international reserves of the Government." xxx xxx xxx Section 11 of the Host Agreement dated July 22, 1951 likewise provides that "the Organization, its assets, income and other property, shall be: (a) exempt from all direct and indirect taxes." In view of the above-quoted provisions of the agreements entered into between the Government of the Republic of the Philippines and the World Health Organization, your request for exemption from the payment of internal revenue taxes on imported articles as well as on those purchased locally for the construction of the WHO building, is hereby granted. You are likewise granted authority to issue certificates of exemption which shall state in detail the kind and quantity of the articles purchased, the vendor and the corresponding item in the plan of the building to be constructed. cdtech Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue