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International comity.

This principle limits the authority of the government to effectively impose taxes on a sovereign state and its
instrumentalities, as well as on its property held and activities undertaken in that capacity. As a rule, the
Philippine government cannot tax foreign ambassadors nor impose real property taxes upon foreign embassies.
(f) Double Taxation. Two types of double taxation are direct double and indirect double taxation.
Direct double taxation – Where:
(1) the same subject is taxed twice;
(2) by the same taxing authority;
(3) within the same jurisdiction;
(4) during the same taxing period; and
(5) covering the same kind or character of tax (Villanueva v. City of Iloilo, L-26521).
There is no constitutional prohibition against double taxation in the Philippines (Villanueva v. City of
Iloilo, L-26521, December 28, 1968), though it is not favoured.
Indirect double taxation, which lacks one or more of the elements of direct double taxation, is also
permissible.

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