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Tax Exemption Granted to Lorenzo Flour Mills

BIR Ruling No. 442-59 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Aug 21, 1959

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August 21, 1959 BIR RULING NO. 442-59 Lorenzo Flour Milla 2689 Taft Avenue M a n i l a Gentlemen : In reply to your letter dated August 6, 1959, I have the honor to inform you that the Lorenzo Flour Mills is considered exempt from the payment of income taxes only up to May 19, 1959, as contemplated in its original certificate of exemption. It is to be observed that under the provisions of Republic Act No. 901, a grantee of tax exemption under said Act or Republic Act No. 35 shall be subject to full income tax after it shall have enjoyed tax exemption for six (6) years. When the Secretary of Finance fixed May 19, 1959 as the terminal date of the exemption of the corporation from the income tax, it is because on said date the corporation shall have enjoyed exemption for six (6) years. Accordingly, the amendment effected to section 1 of R.A. No. 901 by R.A. No. 2351 providing for the imposition of full income tax on income of the tax-exempt industries received from July 1, 1959 finds no application to your case. Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue

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