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Exemption of the Activity of Leasing Market Stall Space from VAT

BIR Ruling No. 252-88 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jun 8, 1988

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June 8, 1988 BIR RULING NO. 252-88 103 (q) 000-00 252-88 M a d a m : This refers to your letter dated May 18, 1988 stating that you are a co-owner of market stalls known as Paraaque Fresh Food Terminal along Aquino Avenue in Paraaque, Metro Manila; and that you leased the stalls to bona fide tenants who regularly pay monthly rentals. Based on the foregoing facts, you request confirmation of your opinion that you are exempt from VAT. In reply, please be informed that lease of market stalls space is lease of real property within the purview of Article 1643 of the Civil Code.Such being the case, your activity of leasing market stall space is exempt from VAT pursuant to Section 103(q) of the Tax Code, as amended by Executive Order No. 273. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner

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