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Tax Exemptions of Toyo Corporation of Japan

BIR Ruling No. 282-87 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Sep 10, 1987

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September 10, 1987 BIR RULING NO. 282-87 45 46 000-00 282-87 Gentlemen : In reply to your letter dated August 12, 1987, please be informed that since under BIR Ruling No. 25-000-00-124-87 dated May 5, 1987, this Office ruled that your client, Toyo Corporation of Japan which is undertaking OECF-assisted projects in the Philippines is exempt from the corporate income tax imposed under then Section 24 (b)(2) [now Section 25 (a)(T)] of the Tax Code, as amended, on resident foreign corporations engaged in trade or business within the Philippines as well as from the 3% (now 4%) contractor's tax and compensating taxes imposed under Sections 205 and 204 (now Sections 170 and 169) of the Tax Code, as amended, and that its foreign personnel shall also be exempt from the individual income tax prescribed under Section 22 of the same Code, as amended, Toyo Corporation of Japan is not required to file quarterly income tax returns and final or adjustments returns on income derived from the aforesaid project. Moreover, its foreign personnel are not also required to file individual income tax returns on income likewise derived from the said project. Very truly yours, (SGD.) EUFRACIO D. SANTOS Deputy Commissioner

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