May 30, 2018

DA ITAD BIR RULING NO. 020-18

Section 106 (A) (2) (b), Tax Code; Article XI (2) (2b), PH-Japan TCA;
BIR Ruling No. ITAD-010-17

Japan International Cooperation Agency

40th Floor Yuchengco Tower, RCBC Plaza

Ayala Avenue, Makati City

Gentlemen :

This refers to your Note No. 123-18 dated 27 April 2018, referred to this office by the Department of Finance and the Department of Foreign Affairs, requesting exemption from the payment of value-added (VAT) and ad valorem taxes on the local purchase of a motor vehicle for the official use of the Japan International Cooperation Agency (JICA), specifically described, as follows: HEITAD

Type of use:

Official

Make:

Toyota Hiace S Grandia 3.0L Dsl A/T 1T-ZO-023

Model year:

2018

Color:

White Pearl

Frame number:

JTFRT13P1J8024606

Engine number:

1KD2794522

In reply, please be informed of Section 106 (A) (2) (b) of the National Internal Revenue Code of 1997, as amended (Tax Code),which provides:

"SEC. 106. Value-Added Tax on Sale of Goods or Properties. —

xxx xxx xxx

(2) The following sales by VAT-registered persons shall be subject to zero percent (0%) rate:

xxx xxx xxx

(b) Sales to persons or entities whose exemption under special laws or international agreements to which...

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