VAT Ruling No. 022-96

September 23, 1996 VAT RULING NO. 022-96 Sec. 102-000-022 Petron Service Station 1630 D. Jose St. Sta. Cruz Manila Attention: Mr . Jorge S . Gonzales Gentlemen : This refers to your letter requesting for an opinion as to who is the proper person liable for the value-added tax on rent. LexLib It is represented that you are private operator of a gasoline station under contract with the Petron Corporation; that the station you operate is situated on a parcel of land owned by third parties who leased it to the Petron Corporation, and in turn leased the same to you; that gasoline dealers have no opportunity nor occasion to apply the same measures to offset the payment of the EVAT and should be applied elsewhere. In reply, please be informed that under Section 4.102-1, the Value-Added Tax on Rental is due from the land owner or lessor of real property. Since the gasoline station operator sells both exempt and non-exempt products, it can only claim as much of the input tax on rental payments in proportion of the VAT taxable sales to the VAT-exempt sales. Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue