February 7, 2020
ITAD BIR RULING NO. 019-20
Articles 3 (Definitions) and 7 (Project Supplies and Professional and Technical Material and Services) Philippines-
Australia Agreement on Development Cooperation
Cardno Emerging Markets (Australia) Pty. Ltd.-
Regional Operating Headquarters Philippines
Level 3B, 111 Paseo de Roxas Building
Paseo de Roxas corner Legaspi Street
Legaspi Village
1229 Makati City
Attention: AAA
______________
Gentlemen :
This refers to your letter dated October 5, 2016 requesting for a clarification on the expanded value-added tax ("VAT") exemption rulings issued to the Philippines-Australia Basic Education Sector Transformation ("BEST") Program and the Philippines-Australia Basic Education for Muslim Mindanao ("BEAM-ARMM") Program, which are both funded by the Australian government under the General Agreement on Development Cooperation between the Government of the Republic of the Philippines and the Government of Australia ("GADC"). HTcADC
In BIR Ruling Nos. 95-16 dated May 16, 2016 and 33-16 dated March 21, 2016, this Bureau held, among others, that services furnished under the BEST Program and the BEAM ARMM Program are subject to zero percent VAT only when rendered by individuals or general partnerships registered in the Philippines. The basis of our ruling is...