B.I.R. Ruling No. 629 is Controlling and Should be Followed

July 7, 1959 BIR RULING NO. 342-59 Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accountants P.O. Box 589, Manila Gentlemen : Reference is made to your letter dated May 12, 1959, inviting the attention of this Office to two rulings issued by it, the first dated July 26, 1956 and the second (B.I.R. Ruling No. 629) October 3, 1958. You stated that said rulings are inconsistent with each other, for which reason you now request information as to which of them should be followed. In answer thereto, I have the honor to inform you that, as B.I.R. Ruling No. 629, series of 1958, is later than the ruling dated July 26, 1956, the former necessarily repeals the latter. Accordingly, B.I.R. Ruling No. 629 is now controlling and should be the one followed. It may be stated that under section 29(b)(7) of the Tax Code, the exemption is limited to the income of foreign governments themselves received from their investments in the Philippines in stock, bonds, or other domestic securities, or from interest on their deposits in banks in the Philippines. Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue