VAT Ruling No. 087-90
VAT Ruling No. 087-90 • Bureau of Internal Revenue (BIR) Issuances • VAT Rulings • Apr 5, 1990
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April 5, 1990 VAT RULING NO. 087-90 102-000-00-087-90 Siguion Reyna, Montecillo and Ongsiako Law Office MCPO Box 760 Makati, Metro Manila Attention: Atty . Jose Leagogo S i r s : This refers to your letter in behalf of your client ROA Global Communications, Inc. (Phil. Branch) (dated May 18, 1989) wherein you represented that its mother company ROA Global Communications (US) entered into a technical service agreement with Philippine Global Communications (Philcom) at an agreed compensation. The payments for said services which are exclusively rendered to Philcom are made through your client ROA Globcom (Philippine Branch). Based on the foregoing, you now request for the confirmation of your opinion that the technical service fees paid by Philcom to your client are not subject to VAT. In reply, please be informed that inasmuch as ROA Global (US) is considered to be engaged in business in the Philippines, it maintaining a branch office here, its sale of technical services, although on an exclusive basis, is subject to 10% VAT pursuant to Section 102(a) of the Tax Code, as amended. Very truly yours, JOSE U. ONG Commissioner of Internal Revenue
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