Air France Subject to 3% Common Carriers' Tax
BIR Ruling No. 169-85 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Sep 25, 1985
Full text
September 25, 1985 BIR RULING NO. 169-85 207 00-85 169-85 Gentlemen : In reply to your letter of September 4, 1985, please be informed that the RP-France Tax Treaty covers only income taxes. Thus, Article 8 (Shipping and Air Transport) thereof providing for the maximum tax that the Philippines may impose in "profit from the operation of ships and aircraft in international traffic" refers only to income taxes. cdti The 3% common carriers' tax not being an income tax, is not covered by the said tax treaty. Hence, Air France like any other airline operating in the Philippines, is still subject to the said 3% common carriers' tax imposed by our Tax Code. Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner
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