An Ordinance Providing for Tax Discounts on Prompt Payment of Real Property Tax, Amending the Mandaluyong City Revenue Code of 2011

March 13, 2008 BIR RULING [DA-154-08] 108; VAT-10-2004 Happy Sanrio Export Trading Corporation 175 LE ITC Road, Bagbaguin Valenzuela City Attention: Mr. George Guiang President Gentlemen : This refers to your letter dated June 14, 2007 requesting for a ruling that the sale of fresh fruits products and the likes to other countries is exempt from the imposition of Value Added Tax. Documents submitted disclosed that Happy Sanrio Export Trading Corporation (Sanrio) is registered with the Securities and Exchange Commission (SEC) with registration certificate number CS200700089 dated January 8, 2007; that the primary purpose of its incorporation is to engage in the exportation of fresh fruits products and the like; and that it is not VAT-registered. In reply, please be informed that Section 4.109-1 of Revenue Regulations No. 16-2005, as amended, provides viz.: (1) SEC. 4.109-1. VAT-Exempt Transactions. xxx xxx xxx (B) Exempt transactions. xxx xxx xxx (o) Export sales by persons who are not VAT-registered; TAIDHa xxx xxx xxx Accordingly, your export sales of fresh fruit products to foreign countries, shall be exempt from VAT. This ruling is issued on the basis of the foregoing facts as represented. However, if upon investigation it shall be disclosed or discovered that the facts are different, then this ruling shall be without force and effect insofar as the parties herein are concerned. Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service