July 9, 2010
BIR RULING [DA-(VAT-021) 121-10]
RR 9-89; RMC 42-2003; 110; 112; VAT Ruling No. 059-92;
BIR Ruling Nos. DA-636-2006; DA-(VAT-086)539-09
JGC Corporation Manila-ROHQ
7th Floor, JGC Phil. Building, 2109 Prime St.
Madrigal Business Park, Ayala Alabang
Muntinlupa City
Attention: Mr. Hiroki Kitajima
Authorized Representative
Gentlemen :
This refers to your letter dated January 19, 2009 requesting for confirmation that the input taxes shifted or passed-on to JGC Manila ROHQ by its local value-added tax (VAT) registered suppliers of goods, properties and services may be recognized outright as an expense for income tax purposes, or be added to the acquisition cost upon purchase of the capital asset subject to depreciation, as the case may be.
It is represented that JGC Corporation Manila-ROHQ ("JGC Manila ROHQ") is a multi-national company organized and existing under the laws of Japan and engaged in the business of IT-enabled engineering, procurement and construction services.
On December 11, 2000, JGC Manila ROHQ registered with the Securities and Exchange Commission (SEC) as a regional operating headquarters in the Philippines for which it was issued a license to engage certain qualifying services, to wit:
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