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July 9, 2010BIR RULING [DA-(VAT-020) 120-10]Section 105; VAT Ruling No. 012-96Mrs. Ellen Rose Manuel-Pineda, CPA2784 Buencamino Street, PoblacionMakati CityMadam :This refers to your letter dated April 3, 2009 requesting in behalf of your client, Calatagan Golf Club, Inc., with Taxpayers Identification No. 000-532-804-000, for confirmation of your opinion that the monthly membership dues billed by it to its members who are stockholders or assignees of the stockholders are not subject to value-added tax (VAT) imposed under Section 108 of the Tax Code of 1997, as amended.It is represented that the Calatagan Golf Club, Inc. was incorporated on April 8, 1976 as a non-profit organization mainly to foster and promote the game and operate and maintain a golf course and country club for social and recreational activities. The golf club bills and collects membership dues from the members primarily to cover expenses related to the maintenance of the golf course facilities and premises of the club. Any excess membership dues over any maintenance expenses are utilized for the improvements of the club facilities. Furthermore, no part...