VAT Ruling No. 024-92

March 11, 1992 VAT RULING NO. 024-92 NIRC Sec. 102 (a) Precedent Ruling 000-00 Paras & Reynes 120 Amorsolo St. Makati, Metro Manila S i r : This refers to your letter dated August 1, 1991 written in behalf of Agence France Presse (Phil. Branch), an international news agency, seeking clarification whether your client's activity, ruled to be exempt from VAT in this Office's ruling issued to Associated Press dated October 22, 1987, is now subject to VAT pursuant to VAT Ruling No. 020-91 dated April 1, 1991, issued to SGV and Co., holding that the activity engaged in by their client, Reuters Ltd., is subject to value-added tax under Section 102 of the Tax Code. In reply, please be informed that VAT Ruling No. 020-91 expressly revoked the unnumbered ruling addressed to Associated Press. Such being the case, the business activity of your client became subject to VAT as of April 1, 1991, considering that a vested right cannot spring from a wrong interpretation of the law. ( Emilio Y. Hilado vs. The Collector of Internal Revenue and the Court of Tax Appeals G.R. No. L-9408, Oct. 31, 1956) In view thereof, you are requested to advise your client, Agence France Presse (Phil. Branch) to register as a VAT-taxpayer with the Revenue District Office having jurisdiction over its principal place of business. CAIHaE Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue