VAT Ruling No. 059-91
VAT Ruling No. 059-91 • Bureau of Internal Revenue (BIR) Issuances • VAT Rulings • Jun 26, 1991
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June 26, 1991 VAT RULING NO. 059-91 Pinnacle Manpower Services, Inc. 201 Florama Bldg., Bautista St. Makati, Metro Manila Attention: Ms . Estrella M . Guzman General Manager M a d a m : This has reference to your application for zero-rate filed last December 28, 1990 stating that your company is a VAT-registered entity engaged in the sale of manpower services to Philippine D-I, Inc., a BOI-registered domestic corporation. In reply, we regret to inform you that your application is denied for lack of legal basis. Pursuant to Sec. 2 of Rev. Reg. No. 2-88, only sales of raw materials to BOI-registered export producers exporting at least 70% of their actual production shall qualify for zero-rating; hence, your sale of services to Philippine D-I, Inc. shall be subject to 10% VAT pursuant to Sec. 102(a) of the Tax Code, as amended. LexLib This finds support in VAT Ruling No. 134-90 dated May 14, 1990. Very truly yours, JOSE U. ONG Commissioner of Internal Revenue
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