BIR Ruling [UN-343-95]

September 20, 1995 BIR RULING [UN-343-95] Asea Brown Boveri, Inc. Km. 20, South Superhighway Sucat, Paraaque Metro Manila Attention: Mr . Walfrido C . Miranda Vice-President, Finance & Administration Gentlemen : This refers to your letter dated June 29, 1995 stating that you are a VAT-registered corporation that belongs to the Top 5,000 Large Taxpayers; that your regular customer, Subic Power Corporation, is a company operating within the Subic Bay Free Port Zone and duly registered with the Subic Bay Metropolitan Authority (SBMA); and that your transactions with Subic Power Corporation involve sales of equipment, spare parts and installations and repairs. Based on the foregoing, you are requesting confirmation of your opinion that your aforesaid transactions with Subic Power Corporation are subject to zero percent (0%). cdtech In reply, please be informed that this Office had ruled that the sale of goods and/or services by a domestic seller to a registered enterprise operating within the Secured Area of the Zone shall be considered as export sales and effectively zero-rated on the part of the seller. (BIR Ruling Nos. UN-107-94 dated March 15, 1994; and UN-311-94 dated November 11, 1994) Such being the case, this Office confirms your opinion that your sales to Subic Power corporation of equipment, spare parts as well as services for installation and repairs are effectively subject to 0%. Your Application for Zero rate will be referred to the Regulatory Operations Monitoring Division, this Bureau, for approval. cdi Very truly yours, ALICIA P. CLEMENO Assistant Commissioner (Legal Service)