Tax Exemption Conferred by the National Internal Revenue Code is Not Withdrawn by Executive Order No. 93

November 27, 1987 BIR RULING NO. 385-87 24 000-00 385-87 Gentlemen : This refers to your letter dated September 4, 1987 requesting a ruling to the effect that the Home Development Mutual Fund (HDMF) otherwise known as the Pag-ibig Fund is still exempt from the payment of taxes notwithstanding the issuance of Executive Order No. 93. In reply thereto, I have the honor to inform you that your request is answered in the negative. Executive Order No. 93 which took effect on March 10, 1987, withdrew all tax and duty incentives granted to government or private entities under general or special laws. Such being the case, the Pag-ibig Fund whose tax exemption has been restored by Letter of Instructions (LOI) No. 1525 effective February 6, 1986 is now subject to tax beginning March 10, 1987. This Office cannot sustain your allegation that Executive Order No. 93 does not apply to HDMF because the tax exemption granted it under P.D. Nos. 1530 and 1752 is conferred under the National Internal Revenue Code. It is noted that said tax exemption is granted by special laws (P.D. Nos. 1530 and 1752) which are not parts of the National Internal Revenue Code. If the tax exemption is conferred by the National Internal Revenue Code, then it is not withdrawn by Executive Order No. 93, which is not true in your case because your tax exemption was granted under special laws. Very truly yours, (SGD.) EUFRACIO D. SANTOS Officer-in-Charge