Royal Embassy of Cambodia

March 16, 2021 ITAD BIR RULING NO. 007-21 Principle of Reciprocity; RMO No. 10-2019, as amended by RMO No. 41-2020 Royal Embassy of Cambodia I Bldg. Senator, Country Space 1 Unit 7A-B/7th Sen. Gil J. Puyat Avenue 1200 Makati City Gentlemen : This refers to your Note No. 030/21/REC.M dated 15 February 2021, indorsed by the Department of Foreign Affairs, Office of Protocol (DFA-OP), requesting for the renewal of the Value-Added Tax (VAT) Certificate previously issued to the Embassy which will expire on 25 March 2021. HTcADC In reply, please be informed that while the Vienna Convention on Diplomatic Relations of 1961 exempts diplomatic missions ( i.e. , embassies and consulates) and their diplomatic agents from all dues and taxes, personal or real, national, regional or municipal, they are, nevertheless, subject to the indirect taxes of a kind which are normally incorporated in the price of goods or services ( e.g. , VAT). However, on the basis of reciprocity, this Office may grant tax privileges to a foreign embassy and to its members on their local purchases of goods and services, provided that they can submit to the Commissioner of Internal Revenue a proof that the foreign government of the concerned embassy allows similar tax privileges to the Philippine Embassy or its personnel on purchases of goods or services in their country. As per the Indorsement of the DFA-OP dated 17 February 2021, and the DFA Matrix of VAT Privileges Enjoyed by the Philippine Foreign Service Posts dated 11 January 2021, the Philippine Embassy and its diplomatic personnel in Phnom Penh, Cambodia enjoy VAT exemption privileges by way of reimbursement/refund . Based on the foregoing, this Office is of the opinion as it hereby rules that, applying the principle of reciprocity, the Royal Embassy of Cambodia and its diplomatic personnel in the Philippines are entitled to the same VAT exemption privileges by way of reimbursement/refund , and not through point-of-sale basis. Hence, the VAT Certificate of the Embassy which will expire on 25 March 2021 shall no longer be renewed. Accordingly, the Royal Embassy of Cambodia and its diplomatic personnel, upon the expiration of their respective VAT Certificates, may proceed to secure the necessary VAT reimbursement/refund on local purchases of goods and services for official use of the Embassy and for personal use of the diplomatic personnel following the guidelines set forth in Revenue Memorandum Order (RMO) No. 10-2019 dated 28 January 2019, as amended by RMO No. 41-2020 dated 27 November 2020. Very truly yours, (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue