VAT Ruling No. 088-92

July 6, 1992 VAT RULING NO. 088-92 NIRC Sec. 115 99 Precedent Ruling 070-92 Atty. Ambrosio M. Lina 1668 Dasmarias Avenue Dasmarias Village Makati, Metro Manila S i r s : This refers to your letter dated May 6, 1992, in behalf of your client, G & S Transport Corporation, stating that your client is principally engaged in the rent-a-car business under the trade name AVIS; that it is engaged in the business of renting vehicles; and pays the 3% common carrier's tax under Section 115 of the Tax Code. Based on the foregoing, you now request for a ruling whether your client's rent-a-car business and its sale of old cars used in said business is subject to the 10% VAT. In reply, please be informed that under VAT Ruling No. 070-92, sale of capital asset, such as old tanker, by a non-VAT registered taxpayer is still subject to 10% pursuant to Sections 99 and 100 of the Tax Code. Accordingly, your client is subject to 10% VAT on its sale of old cars, consistent with aforesaid ruling. IcADSE Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue