VAT Ruling No. 103-99

October 6, 1999 VAT RULING NO. 103-99 Sec. 108 (B) (4)-083-88-103-99 Diamond Container Yard Corporation C-3 Road near cor. Torcillo St., Caloocan City Attention: Mr . Virgilio F. Diaz General Manager Gentlemen : This refers to your letter dated September 17, 1998 requesting for a ruling on whether or not your services in the form of storage and handling, container repair, hauling and chassis rental to several foreign shipping lines through their agents here in the Philippines is subject to the zero percent (0%) VAT or the ten percent (10%) VAT. In reply, please be advised that pursuant to Sec. 108(B)(4) of the Tax Code of 1997, ' services rendered to vessels engaged exclusively in international shipping ' shall be subject to 0% VAT. In a previous ruling, this Office held that charges billed for the services rendered to foreign shipping lines, i.e., storage and handling, container repair, hauling, etc. paid through the local agents are subject to the value-added tax of 0% provided the person rendering the service is VAT-registered; the service is paid for in acceptable foreign currency and accounted for in accordance with Central Bank regulations; the charge for such service is for the account of the foreign principal and billing is made to them through the shipping agents. (VAT Ruling No. 083-88 dated April 14, 1988). It appears that such is the case insofar as your situation is concerned. This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. Very truly yours, Commissioner of Internal Revenue By: (SGD.) SIXTO S. ESQUIVIAS IV Deputy Commissioner Legal & Enforcement Group