VAT Ruling No. 075-92

June 2, 1992 VAT RULING NO. 075-92 R.R. No. 2-88 008-92 Norsophil Metal Resources, Inc. Room 602, Cristina Building corner Legaspi-Herrera Streets Legaspi Village, Makati Metro Manila Attention: Mr. Eduardo G. Pana Director & CF Gentlemen : This refers to your letter dated December 11, 1990 requesting confirmation of your opinion that your sale of chromite, a raw material in the production of ferrochrome, to Ferrochrome Philippines, Inc. (Ferrochrome) from April 1989 to May 21, 1990, or prior to the approval of your application for zero-rating, is exempt from Value-Added Tax. Documents submitted indicates that your are a BOI-registered firm supplying chromite to Ferrochrome, another BOI-registered firm, engaged in the manufacture and exportation of ferrochrome; that a latter of the Board of Investments dated April 14, 1989, which was addressed to this Bureau, stated that for the years 1986, 1987 and 1988, Ferrochrome has exported at least 70% of its ferrochrome production. In reply, please be informed that, based on the foregoing facts, since you and Ferrochrome are BOI-registered firms, your sale of chromite to the latter, prior to the approval of your application for zero-rating (effective May 31, 1990) to the extant of 70% thereof shall be exempt from VAT pursuant to Revenue Regulations No. 2-88. Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue