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Embassy of the Republic of Angola

ITAD BIR Ruling No. 011-21 • Bureau of Internal Revenue (BIR) Issuances • International Tax Affairs Division (ITAD) Rulings • May 19, 2021

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May 19, 2021 ITAD BIR RULING NO. 011-21 Principle of Reciprocity; RMO No. 10-2019, as amended by RMO No. 41-2020 Embassy of the Republic of Angola Unit 1904, The Peak Tower 107 L.P. Leviste Street, Salcedo Village 1227 Makati City Gentlemen : This refers to your Note Verbal Ref: 04/FLP/02/2021 dated 01 February 2021 indorsed by the Office of Protocol of the Department of Foreign Affairs (DFA-OP) on the value-added tax (VAT) exemption of the Embassy of the Republic of Angola and its personnel in the Philippines on local purchase of goods and services. Relative thereto, 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, however, subject to indirect taxes of a kind which are normally incorporated in the price of goods or services ( e.g. , VAT). Nevertheless, 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. ETHIDa As per the letter of the DFA-OP dated 16 March 2021, the accredited diplomatic and consular missions in the Republic of Angola now enjoy VAT refund privileges on their purchases of goods and services incurred starting 01 October 2019. While the Philippines has no diplomatic post in Angola, there is a Philippine Embassy in Lisbon, Portugal which has concurrent jurisdiction over Angola. Based on the foregoing and applying the principle of reciprocity which was reiterated in Revenue Memorandum Order (RMO) No. 10-2019, as amended by RMO No. 41-2020, this Office is of the opinion as it hereby rules that the Embassy of the Republic of Angola and its qualified personnel in the Philippines are entitled to the same VAT exemption privileges by way of reimbursement/refund . Accordingly, the Embassy of the Republic of Angola and its qualified personnel, may proceed to secure the necessary VAT reimbursement/refund on purchases of local goods and services in the Philippines following the guidelines set forth in RMO No. 10-2019, as amended by RMO No. 41-2020. Very truly yours, (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue

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