Internal Revenue Taxes Due from Visiting SEATO Professors

September 4, 1959 BIR RULING NO. 454-59 The Honorable The Secretary of Foreign Affairs M a n i l a S i r : This is in connection with the query of the SEATO regarding the internal revenue taxes that may be due from visiting SEATO professors. In reply thereto, I have the honor to inform you that the members of the SEATO cannot be exempted from payment of internal revenue taxes unless the SEATO Agreement provides for said exemption. A mere draft of an agreement between the SEATO and the Government of the kingdom of Thailand cannot be the basis of the grant of tax exemption. Moreover, this Office doubts whether visiting SEATO professors can be considered members of the said organization. cdi In view thereof, this Office is of the opinion that: (1) Professor Kamol Janlekha of Thailand will be subject to the income tax on individuals prescribed in section 21 of the National Internal Revenue Code. In computing the tax his total gross receipts will include his salary of $7,000.00 and his quarters allowance of $3,000.00. (2) Professor Zacaria de Jesus, Filipino holder of a similar grant will also be subject to the income tax on individuals prescribed in section 21 of the National Internal Revenue Code. (3) Professor Janlekha will be liable for payment of the compensating tax prescribed in section 190 of the National Internal Revenue Code if he imports a car for his personal use. Said tax will be computed on the total landed cost of the car including freight, postage, insurance, commission and all similar charges. (4) Personal effects brought by him when he arrives at Manila are exempt from tax. In connection with your query regarding customs duty, it is suggested that your request be addressed to the Bureau of Customs which has jurisdiction over the matter. Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue