VAT Ruling No. 084-91

October 22, 1991 VAT RULING NO. 084-91 National Economic and Development Authority Amber Avenue, Pasig Metro Manila Attention: Alice C . Avancea Chief, Publications Division M a d a m : This has reference to your letter dated September 28, 1990 stating that, the NEDA Publication Fund is presently engaged in the printing and publication of books and magazines which appear at regular intervals and are sold to the public on subscription basis at fixed prices and that these publications do not carry advertisements. For the production of your publications, you have been contracting the services of private printers who often charge the 10% value-added tax (VAT). Based on the foregoing, you now request exemption from payment of the 10% VAT being charged to you by the printers of your publications. In reply, please be informed that in Section 103(f) of the Tax Code, as amended, several exempt activities are enumerated, namely: printing, publication, importation and sale. Thus, the printing of books and newspaper, magazine review or bulletin which appears at regular intervals with fixed prices for subscription and sale and which is not devoted principally to the publication of advertisements is per se an independent exempt activity. It appears, however, that private printers are the ones printing your publications. If the NEDA itself prints the same, it would have been exempt from VAT. Section 103 (f) does not give NEDA exemption from its indirect tax liability. The private printers could, therefore, legally pass on their VAT payments to NEDA. dctai Very truly yours, EUFRACIO D. SANTOS Deputy Commissioner Officer-in-Charge