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September 28, 2018ITAD BIR RULING NO. 085-18Secs. 106, 108, NIRC of 1997, as amended;Articles 5 & 7, GADC between GPH and GACoffey International Development Pty. Ltd.3rd Floor, JMT Building ADB AvenueOrtigas Centre, Pasig City 1605Attention: AAA_______________Gentlemen :This refers to your letter of 15 January 2018, requesting confirmation that Coffey International Development Pty., Ltd. ("Coffey"), in its role as managing contractor of the Philippines-Australia Public Financial Management for Infrastructure Program ("PFM-I Program"), is exempt from value-added tax ("VAT") on all program supplies, professional and technical materials and services provided for or procured for the implementation of the activities under the PFM-I Program pursuant to the General Agreement on Development Cooperation between the Government of the Republic of the Philippines ("GPH") and the Government of Australia ("GA") ("GADC"). DHITScIt is represented that the GADC was signed in Sydney on 28 October 1994, was ratified and confirmed by Philippine President Fidel V. Ramos on 7 February 1995, and which ratification was concurred in by the Philippine Senate per Senate Resolution adopted on 22 January 1996; that a Subsidiary...