VAT Ruling No. 006-93

February 3, 1993 VAT RULING NO. 006-93 Section 100 (a) (2)-236-90-006-93 Allied Metals, Inc. 460 Pres. E. Quirino Highway Novaliches, Quezon City Attention: Ms . Ma . Luisa B . Umali Chief Accountant S i r s : This refers to your letter dated September 17, 1992 stating that you are a VAT-registered manufacturing company engaged in the fabrication/sale of stainless steel kitchen equipments and that you impose the 10% Value Added Tax on all your local sales. One of your customer is a government institution, specifically, the International Rice Research Institute (IRRI), which claims that they are exempt from the 10% VAT. Based on the foregoing, you now request for a ruling on whether or not your sales to IRRI are exempt from the 10% VAT. In reply, please be informed that under Republic Act No. 2707 and Presidential Decree No. 1620, IRRI enjoys the comprehensive tax exemption privilege "which extends to goods imported and owned by the International Rice Research Institute. . ." (BIR Ruling No. 077-88). Hence, sale of goods to IRRI shall be effectively zero-rated pursuant to Section 100(a)(2) of the Tax Code. cdpr Very truly yours, JOSE U. ONG Commissioner of Internal Revenue