VAT Ruling No. 096-92

August 6, 1992 VAT RULING NO. 096-92 NIRC Sec. 103(s) Precedent Ruling 000-00 University of the East Claro M. Recto Avenue M a n i l a Attention: Mr. Ernesto C. Gallardo VP-Administration S i r s : This has reference to your letter dated June 10, 1992 stating that you are going to renew your permit to operate the University Security Force, the members of which had been hired by your Department for Personnel Services in accordance with the University rules on personnel recruitment and you are utilizing this force solely for your own security purposes. As a requirement for the renewal of the license, you are requesting this Office for a ruling exempting your school from the value-added tax (VAT). In reply thereto, please be informed that since the U.E. is not selling security services to third parties, but is merely recruiting employees to man its own security force, the U.E. is not liable to pay the value-added tax (VAT), pursuant to Section 103(s) of the Tax Code. Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue