VAT Ruling No. 084-92

July 2, 1992 VAT RULING NO. 084-92 NIRC Sec. 103 (j) 115 Precedent Ruling 007-92 Commercial Freight & Storage Phils., Inc. 292 Gen. Luis Street Intramuros, Metro Manila Attention: Mr. Klaus Schroeder President S i r s : This has reference to your letter dated February 22, 1991 stating that you are a newly established corporation primarily engaged in the hauling of empty and loaded containers and your clients are mostly shipping agents of foreign principals, as well as local companies. Based on the foregoing, you now asked if you could pass on to your clients the output VAT for your hauling fees. In reply, please be informed that based on the foregoing facts your business of hauling empty and loaded containers fall under the category of a transportation contractor. Accordingly, it is subject to the 3% common carrier's tax based on its quarterly gross receipts pursuant to Section 115 of the Tax Code, and, hence, exempted from VAT in accordance with Section 103(j) of the same Code. You may, however, pass on to your clients the amount of the 3% common carrier's tax you paid, as part of your service billings. Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue