VAT Ruling No. 041-92

March 26, 1992 VAT RULING NO. 041-92 NIRC Sec. 100 (a) (1) Precedent Ruling 008-92 APV Philippines, Inc. Marcos Alvarez Avenue Talon, Las Pias, 1701 Metro Manila Attention: Mr. Philip L. Niccolls Manager S i r s : This refers to your letter dated January 7, 1992 requesting a ruling as to the taxability of your sale of equipment, components and spare parts to KLT Fruits, Inc., an EPZA registered enterprise, with Certificate of Registration No. 91-038, engaged in the processing of tropical fruits for export. It is represented that APV Phils., Inc. is a BOI-registered entity engaged in the business of fabricating steel products. In reply, please be informed that sale of raw materials, merchandise, supplies, machineries, equipment, spare parts and wares of every description is not subject to internal revenue laws and regulations pursuant to Article 77(1) of the Omnibus Investment Code (E.O. 226). Such being the case, since you are a BOI-registered firm supplying capital equipment and spare parts to a zone enterprise, you are exempt from VAT in accordance with the aforecited provision of law in relation to Section 103(u) of the Tax Code. Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue