Embassy of the Republic of Singapore

June 17, 2020 ITAD BIR RULING NO. 042-20 Principle of Reciprocity; Revenue Memorandum Order No. 10-2019 Embassy of the Republic of Singapore 505 Rizal Drive, Bonifacio Global City 1634 Taguig City, Manila Gentlemen : This refers to your Note No. 282/2019 dated 20 November 2019, indorsed by the Department of Foreign Affairs, Office of Protocol (DFA-OP), requesting for a BIR ruling on the value-added tax (VAT) exemption on the local purchase of goods and services for the Embassy of the Republic of Singapore. 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, however, subject to the indirect taxes of a kind which are normally incorporated in the price of goods or services ( e.g. , VAT). Nevertheless, under the principle 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 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 27 November 2019, the Philippine Embassy in Singapore enjoys VAT exemption privileges on purchase of goods and services through reimbursement/refund basis. Based on the foregoing, this Office is of the opinion as it hereby rules that, applying the principle of reciprocity, and pursuant to Revenue Memorandum Order (RMO) No. 10-2019, the Embassy of the Republic of Singapore in the Philippines is entitled to the same VAT exemption privileges through reimbursement/refund , and not through point-of-sale basis. Accordingly, the Embassy of the Republic of Singapore, upon the expiration of its VAT Certificate, 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. ITAaHc Very truly yours, (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue