BIR Ruling No. 219-82

July 27, 1982 BIR RULING NO. 219-82 290-A 197-81 219-82 Ramie Textiles, Inc. Fifth Floor, JMT Building 6764 Ayala Avenue Makati, Metro Manila Attention: Mr . Macario M . Perez Tax Manager Gentlemen : This refers to your letter dated May 4, 1982 requesting confirmation of your opinion that your corporation is exempt from the payment of the 10% overseas communications tax on outgoing messages imposed by Section 290-A of the Tax Code for the reason that it is preferred pioneer enterprise duly registered with the Board of Investments and therefore exempt from all national internal revenue taxes, except income tax, on a graduated basis. cdt In reply, please be advised that Section 290-A(b) 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 BOI-registered preferred pioneer enterprises are not among those enumerated, it is regretted that your client for exemption from the said tax cannot be granted for lack of legal basis. cdtech Very truly yours, RUBEN B. ANCHETA Acting Commissioner