VAT Ruling No. 051-99

May 10, 1999 VAT RULING NO. 051-99 Sec. 106 R.R. 7-95 4.106-1(d) 051-99 Mundial Development Corporation No. 1 Pasadena, San Juan Metro Manila Attention: Mr . Buenaventura Berris President Gentlemen : This refers to your letter dated March 29, 1999 concerning your request for information whether you are entitled to a cash refund or issuance of a tax credit certificate for your input taxes as of the date of change of your status from a VAT-registered to a Non-VAT registered person. In reply, please be informed that Section 4.106-1 (d) of Revenue Regulations No. 7-95, implementing Section 106 of the old National Internal Revenue Code (now Section 112 as renumbered by R.A. No. 8424) provides: "SEC. 4.106-1. Refunds or tax credits of input tax . (a) Zero-rated sales of goods or properties or services . . . "(d) Any unused input taxes as of the date of retirement, change or cessation of status of a VAT-registered person shall be allowed as credit against any output tax resulting from such change of status and the balance, if any, shall, subject to the filing of an-application within two (2) years from the date of retirement, change or cessation of status, be issued a tax credit certificate/refund." Very truly yours, Commissioner of Internal Revenue By: (SGD.) SIXTO S. ESQUIVIAS IV Deputy Commissioner Local & Enforcement Group