VAT Ruling No. 054-03

December 15, 2003 VAT RULING NO. 054-03 108 (B) (4) 083-2001 Miascor Logistics Corporation Miascor Cargo Center, Ninoy Aquino Avenue Paraaque City Attention: Mr. Fernando V. Detaunan VP/Group Controller Gentlemen : This refers to your letter dated June 26, 2002, requesting for a ruling stating that your (export) cargo handling services rendered to international air carriers are zero-rated for value-added tax (VAT) purposes. It is represented that Miascor Logistics Corporation (MIASCOR) is a domestic corporation engaged in, among others, providing cargo handling services to international carriers such as Air France, China Southern Airlines, Malaysian Airlines, etc.; that such services include cargo acceptance, crating, checking, re-weighing, x-ray, towing out/delivery to the plane side, and temporary warehousing; that such services are paid for in United States dollars either through wire transfer or dollar checks, which are deposited in its dollar depositary account maintained with UCPB Paseo de Roxas Branch. HCITDc In reply, please be informed that such services fall under Section 108(B) of the National Internal Revenue Code of 1997, as implemented by Sec. 3(b) of Revenue Regulations No. 7-95, as amended by Revenue Regulations No. 5-96, relating to "services rendered to vessels engaged exclusively in international shipping" pursuant to the doctrine of ejusdem generic in Statutory Construction. Accordingly, they shall be treated as entitled to the zero percent (0%) VAT. This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation it will be disclosed that the facts are different, then this ruling shall be considered null and void. Very truly yours, (SGD.) JOSE MARIO C. BUAG Deputy Commissioner Legal & Inspection Group