VAT Ruling No. 082-89

April 4, 1989 VAT RULING NO. 082-89 L.C. Diaz and Co. Union-LCD Bldg. A. Bonifacio, Port Area M a n i l a Attention: Atty . Rogelio R . Nacorda Managing-Director Tax Services Division S i r s : This has reference to your letter dated February 7, 1989 requesting confirmation of your opinion as to whether or not the sales by domestic suppliers of merchandise, supplies, machineries, equipment and spare parts, raw materials and other articles to COVERTEK INTERNATIONAL (an EPZA registered enterprise at the Mactan Export Processing Zone) are subject to the 10% value-added tax. In reply, please be informed that such sales by a supplier who is VAT-registered are considered export sales pursuant to Article 77(b) of the Omnibus Investment Code of 1987 (Executive Order No. 226); hence, they are entitled to zero rating [under Section 100(a)(1) of the Tax Code, as amended. For invoicing purposes, the suppliers of your client are required to (a) indicate in their VAT invoices the EPZA Registration No. of the buyer and (b) stamp in the said invoices the following: ZERO RATED SALES AND DELIVERY TO MACTAN EXPORT PROCESSING ZONE. aisadc Very truly yours, EUFRACIO D. SANTOS Deputy Commissioner