VAT Ruling No. 074-92

June 2, 1992 VAT RULING NO. 074-92 NIRC Sec. 102 (a) Precedent Ruling 000-00 Center for Policy and Development Concerns, Inc. (CPDC) 602 Legazpi Towers 200 107 Paseo de Roxas Makati, Metro Manila Attention: Emanuel V. Soriano President S i r s : This has reference to your letter dated April 1, 1991 stating that you are a non-stock, non-profit corporation registered with the Securities and Exchange Commission; that through your core group of professional men, you undertake, among others, research studies in various fields of expertise to serve the people in matters of social, political, cultural, scientific and economic concerns through research and consultancy studies and translate them into viable programs and strategies for the upliftment of the country's deprived and underprivilege; and that among your outputs are a newsletter to be distributed on subscription basis, books, commissioned policy studies, monograms and briefings. Based on the foregoing, you now request exemption from payment of the 10% value-added tax on said transactions/activities. In reply, please be informed that your research and consultancy services are subject to 10% value-added tax pursuant to Section 102(a) of the Tax Code, as amended if your gross sales or receipts in any 12-month period exceeds P200,000. Accordingly, you are required to register for VAT purposes. Otherwise, if your sale of services did not exceed P200,000 and you did not opt to register as a VAT taxpayer, you are only subject to 2% quarterly percentage tax based on your gross sales or receipts pursuant to Section 112, NIRC. With regards to the printing of your newsletters appearing at regular intervals distributed, on a subscription basis, books, commissioned policy studies, monographs and briefings, being part of your research and consultancy services, are also subject to 10% VAT pursuant to section 102 of the Tax Code. However, if that entity is really a non-profit organization exclusively devoted to the service of the people, you may apply for tax exemption under section 26 of the Tax Code. Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue