Cardno Emerging Markets (Australia) Pty. Ltd.

February 7, 2020ITAD BIR RULING NO. 019-20Articles 3 (Definitions) and 7 (Project Supplies and Professional and Technical Material and Services) Philippines-Australia Agreement on Development CooperationCardno Emerging Markets (Australia) Pty. Ltd.-Regional Operating Headquarters PhilippinesLevel 3B, 111 Paseo de Roxas BuildingPaseo de Roxas corner Legaspi StreetLegaspi Village1229 Makati CityAttention: 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"). HTcADCIn 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...