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June 25, 2010BIR RULING [DA-(VAT-016) 109-10]Section 105, 122; RA 9238; BIR Ruling No. 023-09; BIR Ruling 019-05Divina & Uy Law Offices8th Floor, Pacific Star Building,Sen. Gil Puyat AvenueCorner Makati Avenue, Makati CityAttention: Atty. Nilo T. Divinaand Neli A. Raule-LumanogGentlemen :This refers to your letter dated May 3, 2010 requesting for a confirmatory ruling, as regards your position on the non-imposition of Value-Added Tax (VAT) on the sale of receivables by PCCI Finance Corporation (PCCI) to Equicom Savings Bank, Inc. (ESB) The facts, as represented, are as follows:PCCI, with Tax Identification No. 000-855-814-000, is a local financing company organized under by virtue of Philippine Laws engaged in a wide range of financial services such as financing of receivables, purchasing of notes payable on installment and domestic bills, and discounting of lease contracts. On the other hand, ESB, with Tax Identification Number 000-434-017, is a thrift bank registered with the Bangko Sentral ng Pilipinas and engaged in general financing and investment particularly in the business of savings and mortgage banking.You understand that pursuant to Revenue Regulations No....