Determination of the Profit Realized from the Sale of Cars by Persons Exempted Under the MBA

September 14, 1960 BIR RULING NO. 408-60 The Provincial Revenue Officer Olongapo, Zambales S i r : In connection with the determination of the profit realized from the sale of cars by persons exempted under the Military Bases Agreement, which profit is subject to Philippine income tax being income from Philippine sources, you are informed that in the absence of proof as to the actual cost of the cars as established in Department Order No. 289-A (General Circular No. V-268), the Blue Book value of said car at the time of sale may be considered as the cost of the car. The dollar values shall be converted to the official rate of two pesos for every dollar. In this connection, you are also informed that the personnel of the military bases exempt from taxes under the Military Bases Agreement are considered non-resident alien individuals engaged in trade or business in this country on account of the sale of cars and other personal property and are entitled to an exemption of P1,200.00. Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue