VAT Ruling No. 010-00

February 23, 2000 VAT RULING NO. 010-00 106 (A) (2) (a) (5) 013-99 010-00 G.A. Printing Inc. 7713 Saint Paul St. San Antonio Village, Makati City Attention: Ms . Eloisa P . Salazar President Gentlemen : This refers to your letter dated January 6, 2000, requesting confirmation of your opinion that your supply of printing services to Minola Refining Corporation, a PEZA-registered company with Certificate of Registration No. 98-030, is zero rated under the Value-Added Tax law. In reply, please be informed that under Section 3, par. (3) of Revenue Memorandum 74-99, any sale of goods, property or services made by a VAT-registered supplier from the Customs Territory to any registered enterprise operating in the Ecozone, regardless of the class or type of the latter's PEZA registration, is actually qualified for zero-rating and thus legally entitled to the zero percent (0%) VAT. Accordingly, all sales of goods or property to such enterprises made by a VAT-registered supplier from the Customs Territory shall be treated as subject to 0% VAT pursuant to Sec. 106 (A)(2)(a) (5) of the Tax Code of 1997, in relation to Art. 77(2) of the Omnibus Investments Code, while all sales of services to the said enterprises made by VAT registered suppliers from Customs Territory shall be treated effectively subject to the 0% VAT pursuant to Section 108 (B)(3) of the same Code, in relation to the provisions of R.A. 7916 and the "Cross Border Doctrine" of the VAT system. In view of the foregoing. your opinion is hereby confirmed that your sale of service to Minola Refining Corporation, a PEZA-registered company is subject to 0% VAT. With respect to the requirement for an approved application by service contractors for the effective zero-rating, Revenue Memorandum Circular 74-99 shall serve as a sufficient basis to entitle your company to the benefit of zero-rating for the above sale. This ruling is being issued on the basis of the foregoing facts as represented. If .upon investigation, it will be discovered that the facts are different, then this ruling shall be considered null and void. Very truly yours, Commissioner of Internal Revenue By: (SGD.) SIXTO S. ESQUIVIAS IV Deputy Commissioner Legal and Enforcement Group