Exemption of the Gross Receipts Derived from the Sale of Blocked Television Time from VAT

May 4, 1988 BIR RULING NO. 184-88 99 000-00 184-88 Gentlemen : This refers to your letter dated February 17, 1988 requesting in behalf of your clients, Absolute Sound, Inc. and Airtime Specialists, Inc., confirmation of your opinion to the effect that their gross receipts derived from the sale of blocked television time are not subject to the value-added tax. In reply, please be informed that by selling blocked television time which consists of buying and selling TV airtime, your client is not rendering any service; hence, it was held not subject to the then 3% contractor's tax. (BIR Ruling No. 188-83) Neither is your client engaged in the sale of goods which means only movable or tangible objects. [Sec. 2(p), Revenue Regulations No. 5-87] Accordingly, your client is not subject to the value-added tax on its receipts derived from the sale of blocked television time. Pursuant to Section 99 of the Tax Code as amended by Executive Order No. 273, a value-added tax is imposed on any person who in the course of trade or business, sells, barters or exchanges goods, renders services or engages in similar transactions or any person who imports goods. aisadc Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner