VAT Ruling No. 039-89
VAT Ruling No. 039-89 • Bureau of Internal Revenue (BIR) Issuances • VAT Rulings • Feb 22, 1989
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February 22, 1989 VAT RULING NO. 039-89 INGASCO, Inc. 20 - 12th Avenue, Grace Park Caloocan City, Metro Manila Attention: Ms . Nora D . Miguel Comptroller S i r s : This refers to your application for zero rate of your sale of industrial gases to the following: 1. Ionic Circuits, Inc. 2. Sprague Philippines 3. Silitek Corporation In reply, please be informed that the said application is disapproved for lack of legal basis. As ruled by VAT Ruling No. 420-88, your sale of industrial gases to semi-conductor companies is considered a sale of supply and not a sale of a raw material because it does not form part of the exportable product. Such being the case, it is not qualified for effective zero-rating which under Revenue Regulation No. 2-88 is limited only to the sale of raw materials to a BOI-registered export producer exporting at least 70% of its annual production. LLpr Please be guided accordingly. Very truly yours, VICTOR A. DEOFERIO, JR. Deputy Commissioner
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