VAT Ruling No. 013-91

March 19, 1991 VAT RULING NO. 013-91 Bahia Shipping Services, Inc. 3rd Floor, Shipping Center Bldg. 707 A. Soriano Avenue Intramuros, Manila Attention: Cynthia C . Mendoza General Manager S i r s : This has reference to your letter dated November 23, 1990 requesting confirmation of your opinion that the activities performed by your company classified as zero-rated transactions. As represented, your company is an authorized manning agency deploying Filipino seaman onboard foreign vessels; that the agreement with your foreign principals is to screen and interview all seamen applicants, arrange for their medical examination and assist them in the preparation and approval of their deployment; and that the services are to be paid for by the foreign principals in foreign currency inwardly remitted in accordance with the Central Bank rules and regulations. In reply, please be informed that your opinion is hereby affirmed inasmuch as your transactions conform with the requirements set forth in Section 102(a)(2) of the Tax Code as implemented by Section 8(c)(3) of Revenue Regulations No. 5-87 which provides that services performed in the Philippines other than those mentioned in sub-paragraph (1) the consideration of which is paid for in acceptable foreign currency inwardly remitted to the Philippines and accounted for in accordance with the rules and regulations of the Central Bank shall be subject to VAT at 0%. Such being the case, the services rendered by your company to your foreign principals are subject to VAT at zero-rate pursuant to the aforecited provision of law. This finds support in VAT Ruling No. 233-89 dated September 15, 1989. Very truly yours, JOSE U. ONG Commissioner of Internal Revenue