Taxability of the Fairchild Semi-Conductor (HK) Ltd., Philippines, and the (2) TMX Philippines, Inc.
BIR Ruling No. 147-88 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Apr 19, 1988
Full text
April 19, 1988 BIR RULING NO. 147-88 118 (a) 035-83 147-88 Gentlemen : This refers to your letter September 15, 1987 requesting confirmation of your opinion that: (1) Fairchild Semi-Conductor (HK) Ltd., Philippines, and the (2) TMX Philippines, Inc. as registered with the Export Processing Zone Authority (EPZA) are exempted from the 10% overseas communications tax prescribed under Section 118(a) of the Tax Code. cdt In reply, please be informed that Section 290-A(b) (now Section 118) of the Tax Code explicitly limits the exemption from the payment of the 10% overseas communications tax to only four (4) entities, namely: 1. Government 2. Diplomatic Services 3. International Organizations, and 4. News Services It appearing that Export Processing Zone Authority (EPZA) registered enterprises namely: (1) Fairchild Semi-Conductor (HK) Ltd., Philippines and the (2) TMX Philippines, Inc. are not among those enumerated therein they are subject to the 10% overseas communications tax under Section 290(A) now Section 118) of the Tax Code, as amended. cd Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner
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