BIR Ruling No. 106-83

June 16, 1983 BIR RULING NO. 106-83 Gentlemen : In reply to your letter dated September 16, 1982, please be informed that as a corporation registered with the Board of Investment on June 19, 1981 under Certificate of Registration No. 81-054 as a preferred pioneer enterprise for the production/manufacture and export of phosphatic fertilizers, you are exempt from all internal revenue taxes except income tax on a graduated basis, pursuant to Section 8(a) of R.A. 5186, as incorporated in Article 46(a), Chapter II of Title IV of P.D. No. 1789, otherwise known as the Omnibus Code, to the following extent: cd (1) One hundred per cent (100%) for the first five years; (2) Seventy-five per cent (75%) for the sixth through the eight years; (3) Fifty per cent (50%) for the ninth and tenth years; (4) Twenty per cent (20%) for the eleventh and twelfth years; and (5) Ten per cent (10%) for the thirteenth through the fifteenth year. However, the above exemption privilege which includes exemption from documentary stamp tax, 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. (Section 6, Rule XV, Rules and Regulations implementing P.D. No. 1789) cdta Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue