VAT Ruling No. 021-92

March 11, 1992 VAT RULING NO. 021-92 NIRC Sec. 102 (a) (2) Precedent Ruling 002-91 United Salvage & Towage (Phils.), Inc. Tabacalera Compound, 900 N. Romualdez St. Paco, Manila Attention: Jose Mari Moraza General Manager S i r s : This refers to your letter dated April 24, 1991 inquiring whether services paid for in foreign currency qualify for zero-rated value-added tax. In reply, please be informed that pursuant to Section 8(c)(3) of Revenue Regulations No. 5-87 implementing Section 102(a)(2) of the Tax Code, as amended, services paid for in acceptable foreign currency inwardly remitted and duly accounted for under Central Bank regulations qualifies for zero-rating. Accordingly, your sale of services taxed at zero-rate shall not result in any output tax. The input taxes on your purchases of goods or services related to such zero-rated sales may be applied for a Tax Credit Certificate or be refunded to the extent that such taxes have not been previously applied against output taxes, in accordance with Section 16 of said Revenue Regulations. CcADHI Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue