4/7/2021
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'Gross Philippine Billings' as defined hereunder:
xxx
(b) International Shipping.- 'Gross Philippine Billings' means gross revenue
whether for passenger, cargo or mail originating from the Philippines. up to
final destination, regardless of the place of sale or payments of the passage
or freight documents.
xxx
[9] Rollo, pp. 111-114.
[10] Id. at 114-115.
[11] Id. at 116.
[12] AN ACT RECOGNIZING THE PRINCIPLE OF RECIPROCITY AS BASIS FOR THE
GRANT OF INCOME TAX EXEMPTIONS TO INTERNATIONAL CARRIERS AND
RATIONALIZING OTHER TAXES IMPOSED THEREON BY AMENDING SECTIONS 28(A)(3)
(a), 109, 118 AND 236 OF THE NATIONAL INTERNAL REVENUE CODE (NIRC), AS
AMENDED, AND FOR OTHER PURPOSES.
[13] Revenue Regulations Implementing Republic Act No. 10378 entitled "An Act
Recognizing the Principle of Reciprocity as Basis for the Grant of Income Tax
Exemptions to International Carriers and Rationalizing Other Taxes Imposed thereon by
Amending Sections 28 (A)(3)(A), 109, 118 And 236 of the National Internal Revenue
Code (NIRC), as amended, and for other Purposes."
[14] With applications for a temporary restraining order and a writ of preliminary
injunction, rollo, pp. 136- 165.
[15] Id. at 139.
[16] Id. at 141-146.
[17] Id. at 149.
[18] Id. at 150-151.
[19] Id. at 152.
[20] Id. at 155.
[21] Id. at 160.
[22] Id. at 411-426.
[23] Id. at 417-418.
[24] Id. at 420-424.
[25] Id. at 424.
https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/65912
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