VAT Ruling No. 047-92

March 31, 1992 VAT RULING NO. 047-92 NIRC Sec. 101 Precedent Ruling 000-00 International Brokerage Corporation Rm. 310-C Regina Building 410 Escolta, Manila Attention: Mr. Estelito C. Bagunas Licensed Customs/Broker Gentlemen : Referring to your letter dated January 6, 1992, to the Department of Finance Revenue Services, which was referred to this Office in its 1st Indorsement, dated January 29, 1992, please be informed that under Section 99, NIRC, "any person who imports goods" shall be subject to the 10% value-added tax, regardless of whether or not the said importer is engaged in business and whether or not his business is subject to VAT or to the percentage tax. In view thereof, your client, PASCUAL LINER, INC., is subject to the 10% VAT prescribed in Section 101 of the Tax Code, on its importation of fourteen (14) units of used passenger Isuzu Town buses notwithstanding that your client is engaged in business as a common carrier and subject to percentage tax as a common carrier. Hence, your request that the said importation be exempted from the 10% VAT is hereby denied for lack of legal basis. DSAICa Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue