BIR Ruling No. 130-84

July 31, 1984 BIR RULING NO. 130-84 21-f-060-83-130-84 Gentlemen : This refers to your letter dated November 2, 1982 requesting a ruling as to whether the compensation paid to Dr. Leonardo A. Paulino, who is an employee of the International Food Policy Research Institute (IFPRI) is exempt from Philippine income tax. It is represented that Dr. Leonardo A Paulino is a Filipino citizen and a holder of a G-4 visa; that IFPRI is one of the research centers supported by the Consultative Group on International Agricultural Research (CGIAR) of which the Philippines is a member; that effective 1982, the United States Government has designated IFPRI as a public international organization entitled to enjoy the privileges, exemptions and immunities conferred by the International Organizations Immunities Act; and that said designation includes exemption from the U.S. Federal income tax for members of the IFPRI staff who are not U.S. nationals and who are holders of a G-4 visa issued by the State Department. In reply, please be informed that while the U.S. government has granted exemption from U.S. Federal income tax for members of the IFPRI staff who are not U.S. nationals and who are holders of G-4 visa, this Office believes that it would not be the proper basis to grant similar exemption. Imposition of taxes on official's salaries in the normal course of administration is within the jurisdiction of the national's state. While the U.S. government has designated IFPRI as a public international organization, it cannot be considered in the same footing as the United Nations as well as the organizations created by it. In view thereof, and since Dr. Leonardo A. Paulino is considered a non-resident citizen, compensation for his services rendered to IFPRI is subject to Philippine income tax under Section 21(f) of the Tax Code, as amended. adc Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner