VAT Ruling No. 044-93

December 9, 1993 VAT RULING NO. 044-93 Section 102 (a)-504-88-044-1993 Remington Metal Products 95 Industry Road 2 Malabon, Metro Manila Attention: Mr . Su Inguan Inocencio Proprietor S i r s : This refers to your letter stating that your company provides subcontracting services; i.e. pressing B.I. sheets into speaker frames, for an EPZA-registered company, and that you are paid for on a per piece basis. Based on the foregoing you now request for a clarificatory ruling on whether or not your sale of services to the EPZA-registered company is exempt from the 10% value-added tax (VAT). In reply, please be informed that your sale of services to the EPZA-registered company does not meet the requirements for exemption as provided for in Section 3 of Revenue Regulations No. 2-88. Such being the case, the sale of services is subject to the 10% VAT pursuant to Section 102(a) of the Tax Code. However, said subcontracting services may be exempt from VAT provided that such activity is registered with the BOI and that it is for the processing, converting and manufacture of goods of a BOI-registered company exporting at least 70% of its total output. LLjur Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue