VAT Ruling No. 011-92

January 27, 1992 VAT RULING NO. 011-92 NIRC Sec. 102 Precedent Ruling 000-00 SGV and Company 6760 Ayala Avenue Makati, Metro Manila Attention: Mr. C. C. Gison Tax Division Gentlemen : This refers to your letter dated April 24, 1991 in behalf of your client, World Trade Center Metro Manila, requesting confirmation that exhibition fees and or rental receipts intended to be derived by your client in leasing booth for exhibition purposes will be exempt from the 10% value-added tax. It is represented that World Trade Center Metro Manila (WTCMM) will organize a fair to promote real properties, construction and other related activities, as well as financing schemes and loan packages; that the fair will be opened to all property owners, real estate developers, brokers, banks, construction material manufacturers and suppliers, furniture manufactures, landscapers and architectural, engineering and construction firm; that a contract for participation will be executed by WTCMM and the exhibitors who will be assigned booths to showcase their products; and that as a consideration thereof, the exhibitors will pay WTCMM exhibition fees or rental income. In reply, please be informed that leasing booths to exhibit or showcase products of different producers to enhance the sale thereof; and for such lease the owners of products (property owners, real estate developers, brokers; banks, construction material manufacturers and suppliers, furniture manufacturers, landscapers and architectural engineering and construction firms) would pay your client exhibition or rental fees, is clearly a sale of service under Section 102 of the Tax Code and, therefore, subject to the 10% VAT. ETAICc Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue