Importation of Religious Booklets which are Exempt Under International Laws are also Exempt from VAT

December 28, 1993 BIR RULING NO. 542-93 IMPORTATION OF RELIGIOUS BOOKLETS WHICH ARE EXEMPT UNDER INT'L LAWS ARE ALSO EXEMPT FROM VAT 101 (U) 000-00 542-93 Church of the Living God Alconville Subd., in front of Cosmos Bottling Co. National Highway, San Pedro, Laguna Attention: Mr . Danilo P . Bernardo Pastor This refers to your letter dated May 31, 1993 requesting exemption from the value-added tax on the importation of 25,820 copies of religious booklets; 12.847 pieces of pre-recorded audio cassette taxes and 100 units of audio cassettes players which were donated to you by The Voice of God Recordings, Inc. of Jeffersonville, Indiana, U.S.A. It is represented that you are a non-stock, non-profit religious corporation; that your objective is to propagate the Gospel of Jesus Christ and to unite people of similar faith in the bonds of brotherly and sisterly love fellowship; that upon the favorable recommendation of UNESCO National Commission of the Philippines, you had been granted by the Department of Finance in its 1st Indorsement dated May 27, 1993, exemption from the payment of customs duties pursuant to the provisions of Annexes C(iii) and D(a)(b) of the UNESCO Florence Agreement. aisadc In reply, please be informed that pursuant to Section 103(u) of the Tax Code, as amended by Executive Order No. 273 and implemented by Section 9(b)(16) of Revenue Regulations No. 5-87 dated September 1, 1987, transactions which are exempt under special laws or international agreements to which the Philippines is a signatory, are exempt from the value-added tax. Accordingly, the importation of 25,820 copies of religious booklets and 12,874 pieces of pre-recorded audio cassette tapes covered by Invoice No. VCR-0282 dated April 21, 1993 coming from the U.S.A. are exempt from the value-added tax pursuant to the UNESCO Florence Agreement under Annex A(i) classified as "Printed Books" and Annex C(iii) classified as "Sound Recordings", respectively. However, the importation of 100 units of audio cassette players is subject to the value-added tax since it is not classified as "Scientific Instruments or Apparatus." LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue