Non-exemption on the Delivery of Bonded Fuel Oils

September 9, 1960 BIR RULING NO. 393-60 The Caltex (Phil.), Inc. P. O. Box 783, Manila Gentlemen : In your letter dated July 13, 1960 you made reference to our letter to you dated January 2, 1958 and B.I.R. Ruling No. 87, s. 1958 wherein we held that bonded gasoline and fuel oils consumed by foreign airlines outside of Philippine territory are exempt from the specific tax, subject to the conditions stated in said letter and ruling. You now request information in which of the following cases of delivery of bonded fuel oils will said exemption apply: "1. Deliveries to vessels of Foreign Registry coming in and leaving the Philippine; "2. Deliveries to vessels of Foreign Registry coming in and touching several ports before leaving the Philippines; "3. Deliveries to vessels of Philippine Registry engaged in foreign trade; and "4. Deliveries to vessels of Philippine Registry engaged in Coastwise trade." In answer, I have the honor to inform you that, for lack of legal basis, the exemption in question does not apply to any of the cases mentioned above. the Philippines is not a signatory to any agreement regarding vessels unlike in the case of air crafts the exemption for which is provided for in the Chicago Convention of International Civil Aviation. LLphil Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue