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Exemption from Documentary Stamps Tax on Checks for the U.S. Dollar Account Maintained by the Embassy of Israel

BIR Ruling No. 246-81 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Dec 3, 1981

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December 3, 1981 BIR RULING NO. 246-81 228-00 000-00 246-81 Security Printing Plant Bangko Sentral ng Pilipinas East Avenue Diliman, Quezon City Attention: Mr . Edmundo L . Angeles Acting Director Gentlemen : In connection with your letter received by us on February 20, 1981, requesting confirmation, for and in behalf of the Embassy of Israel, regarding the claims for exemption from the payment of documentary stamps on checks for the U.S. Dollar Account held by the said Embassy in the Bank of America, I have the honor to inform you that pursuant to Section 34 of the Vienna Convention on Diplomatic Relations adopted at Vienna on April 18, 1961, diplomatic agents are exempt from all dues and taxes , personal or real, national, regional or municipal, except : a. indirect taxes of a kind which are normally incorporated in the price of goods or services; b. dues and taxes on private immovable property situated in the territory of the receiving State, unless he holds it on behalf of the sending State for the purposes of the mission; c. estate, succession or inheritance duties levied by the receiving State, subject to the provisions of paragraph 4 of Article 39; d. dues and taxes on private income having its source in the receiving State and capital taxes on investments made in commercial undertakings in the receiving State; e. charges levied for specific services rendered; and f. registration, court or record fees, mortgage dues and stamp duty, with respect to immovable property, subject to the provisions of Article 23. It is clear from the foregoing that documentary stamps tax on checks for the U.S. Dollar Account maintained by the said Embassy in the Bank of America does not fall within the purview of anyone of the aforementioned exceptions. Accordingly, the claims for exemption from the payment of the said tax is hereby granted. cdtech Very truly yours, RUBEN B. ANCHETA Acting Commissioner

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