Non-extension of the Privilege Ordinarily Enjoyed by a Regular Governmental Agency

October 7, 1959 BIR RULING NO. 490-59 Hon. Pedro M. Gimenez United Nations Associations of the Philippines Padre Faura Street, Manila S i r : This refers to your letter dated September 4, 1959 reiterating your request for exemption from the payment of amusement tax due on the admission fees collected from the benefit show held on September 3, 1959 by the United Nations Association of the Philippines at the Lyric Theater. It is noted that your request is based on your claim that the United Nations Association of the Philippines is an organization that has a semi-official status, for the following reasons: a. That it is a creation of the United Nations Division of the Department of Foreign Affairs; b. That the Executive Secretary of this organization is an employee of the Department and that the UNAP is housed in a room provided by the said Department; and c. That the equipment used by the Association in the conduct of its affairs belong to the Department of Foreign Affairs. This Office does not find itself in a position to dispute the foregoing assertions. Granting the same to be true, the semi-official status of the association cannot be the basis for the extension of the privilege ordinarily enjoyed by a regular governmental agency. Accordingly, your request has to be, as it is hereby denied. aisadc Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue