VAT Ruling No. 063-92
VAT Ruling No. 063-92 • Bureau of Internal Revenue (BIR) Issuances • VAT Rulings • May 18, 1992
Full text
May 18, 1992 VAT RULING NO. 063-92 NIRC Sec. 100 (a) Precedent Ruling 000-00 Mr. Hermelo C. Bacani Assistant to the President Phelps Dodge Philippines, Inc. No. 2 Pioneer St., Mandaluyong Metro Manila S i r : This refers to your letter dated September 4, 1991 addressed to the Board of Investments (BOI) which was indorsed to this Office by the latter on November 5, 1991 requesting for the zero-rating of your sale of soundronic wires to Del Monte Phils., Inc. (DMPI) under the provisions of Section 2 of Revenue Regulations (RR) No. 2-88. It appears that DMPI is a foreign-owned domestic corporation engaged in the development and cultivation of agricultural lands, planting, harvesting, processing, packing and selling of products of said lands, that while it is a BOI-registered enterprise covered by Certificate of Authority No. 933 dated April 20, 1990 it is authorized merely to accept additional investments from its parent company but does not export its products abroad. In reply, please be informed that your sale of soundronic wires to DMPI will not qualify for zero-rating in as much as DMPI is not a BOI-registered exporter of goods as required under RR No. 2-88. Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue
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