Request for Tax Exemption Certification of Pan American World Airways System

September 24, 1959 BIR RULING NO. 502-59 Pan American World Airways System Manila International Airport Nichols Field, Pasay City Gentlemen : This is in connection with your request for certification that the Pan American World Airways System is exempt from all taxes under its franchise, Act No. 4249. It appears from your letter that this certification is being requested upon requirement of the Collector of Customs. Section 12 of Act No. 4249 provides: "In consideration of the franchise and rights hereby granted, the grantee shall pay to the Insular Government during the first ten years of the life of this franchise a tax of one per cent of the gross revenue derived by the grantee from its operation under this franchise; and during the remainder of the life of this franchise a tax of two per cent of such gross revenue. Such tax shall be due and payable quarterly and shall be in lieu of all taxes of any kind, nature or description, levied, established or collected by any municipal, provincial or insular authority . The grantee shall pay the tax on its real property in conformity with existing law." Based on the aforequoted provision of your franchise, I have the honor to inform you that, upon payment of its franchise tax, the company is exempt from any other internal revenue tax. In respect to customs duties and other taxes, the query should be directed to the office or bureau charged with the administration and enforcement thereof. aisadc Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue