VAT Ruling No. 031-93

May 10, 1993 VAT RULING NO. 031-93 Section 2-88 102-92 031-93 Kodak Philippines, Ltd. 1258 Makati Metro Manila Attention: Ms . Arlene C . Artillero Accounting Supervisor S i r s : This is with reference to your letter dated December 8, 1992 stating that your company supplied animation cells and motion picture negative films to Kennedy Cartoons Manila, Inc. a BOI-registered company exporting 100% of its products; and that said animation cells and motion picture negative films are to form part of the finished products to be exported by Kennedy Cartoon Manila, Inc. Based on the foregoing, you now request for a ruling on whether or not your sale of animation cells and motion picture negative films to Kennedy Cartoons Manila, Inc. is zero-rated. In reply, please be informed that since the animation cells and motion picture negative films your company sold to Kennedy Cartoon Manila, Inc. qualifies as raw materials which shall form part of the finished products to be exported by the latter, said sale shall be subject to zero-rate VAT in accordance with Section 2 of Revenue Regulations No. 2-88. Very truly yours, JOSE U. ONG Commissioner of Internal Revenue