Bureau of Local Government Finance Opinion

July 16, 2012 BUREAU OF LOCAL GOVERNMENT FINANCE OPINION Ms. Margarita S. Ibayan Director for Immunities and Privileges Office of Protocol Department of Foreign Affairs 2330 Roxas Blvd., Pasay City Madam : This has reference to your 1st Indorsement dated May 8, 2012 pertaining to the request of the Embassy of Japan for the issuance of a certificate of exemption or ruling from the payment of real property tax in relation with the sale of its property in the Philippines. In view thereof, please be informed that under Article 23 of the Vienna Convention on Diplomatic Relations (Convention adopted on April 18, 1961, it is provided that: "Article 23 of the Vienna Convention provides: "1. The sending state and the head of the mission shall be exempt from all national, regional or municipal dues and taxes in respect of the premise of the mission, whether owned or leased, other than such as represent payment for specific services rendered. "2. The exemption from taxation referred to in this Article shall not apply to such dues and taxes payable under the law of the receiving state by persons contracting with the sending or the head of the mission." xxx xxx xxx Premises considered, the aforequoted provision of the convention is clear that the Embassy of Japan is exempt from the real property tax on its real properties in the Philippines. EDcICT Very truly yours, (SGD.) SALVADOR M. DEL CASTILLO OIC-Executive Director