The Eight Security Training Center, Inc.

October 23, 2008 BIR RULING [DA-(VAT-017) 332-08] Section 22 (B); DA-450-2004 The Eight Security Training Center, Inc. 2F Manila Memorial Park Bldg. 2283 Pasong Tamo Ext., Makati City Attention: Ma. Roxanne A. Singson President Gentlemen : This refers to your letter dated July 22, 2008 requesting for a ruling to the effect that the services rendered by your company as a private educational institution is exempt from Value Added Tax (VAT). It is represented that The Eight Security Training Center, Inc. is duly incorporated with the Securities and Exchange Commission per CR No. A200115682; and that it was granted by Technical Education and Skills Development Authority (TESDA) an accreditation to offer programs in Security Services NC I and II per WTR Nos. 0713051685 and 0713051686. In reply please be informed that Sec. 109 (H) of the National Internal Revenue Code of 1997 (NIRC), as amended states: "SEC. 109. Exempt Transactions. (1) Subject to the provisions of Subsection (2) hereof, the following transactions shall be exempt from the value-added tax. xxx xxx xxx (H) Educational services rendered by private educational institutions, duly accredited by the Department of Education (DepEd), the Commission on Higher Education (CHED), the Technical Education and Skills Development Authority (TESDA) and those rendered by government educational institutions." HTSaEC Thus, under the NIRC, as amended, TESDA recognized or accredited institutions are exempt from VAT pursuant to Section 109 (H) thereof. In view of the foregoing, The Eight Security Training Center, Inc., a TESDA recognized or accredited institution is exempt from VAT. This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation it will be disclosed that the facts are different, then this ruling shall be considered null and void. Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service