VAT Ruling No. 003-93
VAT Ruling No. 003-93 • Bureau of Internal Revenue (BIR) Issuances • VAT Rulings • Jan 14, 1993
Full text
January 14, 1993 VAT RULING NO. 003-93 Section 102 (a) (2)-001-93-033-93 Hitachi, Ltd. 6 Kanda Surugadal 4 Chome Chiyoda-Ku, Tokyo, Japan Attention: Mr . K . Tanaka Deputy General Manager Accounting Control Department Gentlemen : In connection with the letter of your legal counsel (Jose M. Maronilla & Associates) dated January 5, 1993 and further to our VAT Ruling No. 001-93 dated January 4, 1993, please be informed that such portion of the Philippine contractors' services which you pay in foreign currency directly from Japan and remit inwardly to the Philippines in accordance with Central Bank rules and regulations shall not form part of the gross receipts or earnings of your branch office in the Philippines for purposes of imposing the value-added tax. We also confirm your opinion that any amount received from the head office (Tokyo, Japan) and booked as part of the Manila branch gross receipts, in connection with the project (Malaya Gas Turbine, Sucat 1 & 4 Rehabilitation Project) shall, likewise, be exempt from VAT. LexLib Very truly yours, JOSE U. ONG Commissioner of Internal Revenue
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