VAT Ruling No. 012-98

April 21, 1998 VAT RULING NO. 012-98 Sec. 113-A-000-00-012-98 Philippine Ports Authority Marsman Bldg., 22 M. de San Francisco South Harbor, Manila 1018 Attention: Mr . Pablo S . Ong Assistant General Manager Finance and Administration Service Gentlemen : This refers to your letter dated June 9, 1997 requesting for reconsideration of this Office's ruling dated February 14, 1995 denying your request for exemption from issuing separate VAT and Non-VAT Official Receipts on your VAT and Non-VAT taxable transactions. LexLib It is represented that Philippine Ports Authority is a government-owned and controlled corporation rendering VAT and VAT-exempt services to thousands of port users/clients daily; that in order to avoid complicated operations, high printing costs, voluminous transactions, files and complaints from queuing ship passengers, cargo owners, cargo handlers and other port users, you are reiterating your request for exemption from the rule that " if the taxable person is also engaged in exempt transactions, he should issue separate invoices or receipts for the taxable and exempt transactions "; that in order to properly account for the taxable and exempt transactions, two separate portions showing the "Vatable Revenue" and the "Non-Vatable Revenue" are shown in the sample of submitted Official Receipt clearly indicating the billing for items which are taxable and exempt, respectively. In reply, please be informed that Section 113-A of the Tax Code of 1997 as enunciated in Section 4.108-1 of Revenue Regulations No. 7-95 requiring the issuance of separate invoices or receipts for taxable and exempt operations is categorically clear and unequivocal. Such being the case, we regret to inform you that your request for reconsideration of the denial for the privilege to use multipurpose Official Receipt to cover both your VAT and Non-VAT transactions is hereby denied for lack of legal basis. casia Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue