VAT Ruling No. 105-89
VAT Ruling No. 105-89 • Bureau of Internal Revenue (BIR) Issuances • VAT Rulings • Apr 21, 1989
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April 21, 1989 VAT RULING NO. 105-89 Albano, Garcia & Diaz Law Offices Suite 201, L & F Bldg., 107 Aguirre St. Legaspi Village, Makati, Metro Manila Attention: Ms. Emiluz E. Pascasio S i r s : This refers to your letter dated October 21, 1988, requesting for a ruling to confirm that your law firm, which is a general professional partnership, is not covered by the Value-Added Tax. In reply, please be informed of the following: 1. As per Revenue Memorandum Circular No. 18-88, "the value-added tax, the amount of which cannot be fixed, determined, computed or ascertained at the time of such payments by the government offices, instrumentalities and agencies is not subject to the withholding provisions". 2. Under Section 103 (r) of the Tax Code, as amended by Executive Order No. 273, your law firm, which is a registered general professional partnership, is exempt from the value-added tax. Thus, there is no legal basis for your clients to deduct 10% VAT from the retainership fees paid to your firm. HTScEI Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue
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