VAT Ruling No. 012-90
VAT Ruling No. 012-90 • Bureau of Internal Revenue (BIR) Issuances • VAT Rulings • Jan 18, 1990
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January 18, 1990 VAT RULING NO. 012-90 Mr. Ernesto M. Maloles Suite 305 FHL Bldg., Aguirre St. Legaspi Village, Makati Metro Manila S i r : This is in reply to your letter dated January 20, 1989 requesting clarifications in behalf of your client who is engaged in T.V. airtime "blocktiming". It is represented that as a "blocktimer", he buys the rights to a featured film or television "series" to be exhibited on television. In the process, he secures a contract from a television station to buy a time slot on television and sells advertising airtime to advertising agencies or directly to companies that advertises their products over television. You are now inquiring on whether such sale of advertising airtime is subject to the Value-Added Tax (VAT). In reply, please be informed that the sale of airtime to companies who wish to advertise their products is not subject to VAT since "such business activity is not a sale of services, labor or goods but a sale of intangible property rights". (VAT Ruling #021-88 dated February 11, 1988). aisadc Very truly yours, JOSE U. ONG Commissioner of Internal Revenue
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