Does failure to mention mean exemption in taxation

Question

I've got some legal question, this might be just a semantic/language question. My colleagues and I have been arguing about this for some time now, because there's some level of ambiguity in the legal article below:

Context :

The company is a non-stock/non profit international organization, therefore there are globally and locally recruited staff.

Problem :

Assuming that this is the only legal article encompassing taxation, and no other mentions can be found, particularly in no. 3, wherein it states there that Non-Filipino citizens are exempt from paying income taxes.

It explicitly states that non-Filipino - European, American etc. are exempt. But does this imply that Filipino citizens are required to pay income taxes? I mention required with the common understanding that all individuals receiving compensation/income by definition are "profiting" from the employment.

There are no mentions of Filipino being "required" or "exempted", thus the ambiguity on whether Filipino citizens should pay or not.

Answer 1

This isn't ambiguous at all.

Article 5, Section 3 means what it says, non-Filipino citizens are exempt to the extent provided. Everyone else (and all income not exempted by Article 5, Section 3 for those with exemptions) is taxed to the same extent it would be if that individual was not affiliated with the Institute.

Thus, Filipino citizens receiving salaries and stipends for service on the senior administrative and professional staff owe taxes to the same extent as they would if they worked somewhere other than the Institute. In practice, this probably means that they are required to pay taxes (at least if they make enough money to owe taxes). There is no fair reading of this Article which would mean that they are exempt from paying taxes.

Answer 2

The problem appears to arise from "Assuming that this is the only legal article encompassing taxation". This item (which I assume is some aspect of law in The Philippines, is not the only word on taxation, as you can see here. Section 24 of the tax law imposes an income tax on individuals; application of the income tax requirement differ as to citizen vs. resident status.

It is a linguistically normal but defeasible inference that if certain people are declared to be exempt from a requirement that there must be other people who are not exempt, but that is not what this particular piece of law says. If nobody had to pay tax, it might be senseless to say that certain people don't have to pay tax; but there could be many reasons why such an apparently senseless statement is made. The usual reason under the law is that there used to be a broader requirement which was changed, and not all parts of the code were amended to reflect the change. Rather than having to modify the law that says "Everybody pays taxes", a law is passed that says "These people don't pay taxes", and the parts are connected via some clause that says "except as otherwise provided by law".

Outside of law, there is the linguistic study of "pragmatics" which looks at the mechanisms of inference behind people's leaps from what was literally said to what they think must have been meant. Whether or not the law operates in terms of literal statements versus pragmatic inferences is a mixed bag, but the general pattern is that statutes which tell people what they must do are interpreted according to literal statement (or legislative intent when literal statement is not patently obvious), but contractual relations are based on "reasonable interpretation", i.e what a reasonable person would have thought was intended.