VAT Ruling No. 038-93

August 9, 1993 VAT RULING NO. 038-93 Section 100 (a) 010-00 038-93 Ecoplastics Philippines, Inc. Teresita Drive, 2nd Avenue Sta. Maria Subd., Bagong Tanyag Taguig, Metro Manila Attention: Mr . Vicente Lim S i r s : This refers to your letter dated May 11, 1993 requesting for a ruling that your sales of hangers to a garment exporter be subject to zero-rate VAT inasmuch as VAT Ruling No. 010-93 allows sales of packaging materials to be zero-rated. In reply, please be informed that VAT Ruling No. 010-93 explicitly states that the transaction which qualifies for zero-rating refers only to the sale by a supplier to a BOI-registered manufacturer-exporter of packaging materials that either form an integral part of, or are indispensable in the marketing and handling of finished products exported. Since hangers are not packaging materials, your sales thereof to an exporter of garment cannot be zero-rated and hence subject to the 10% VAT in accordance with Section 100 (a) of the Tax Code. prcd Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue