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October 1, 2018ITAD BIR RULING NO. 086-18Section 109 of NIRC of 1997, as amended;Articles 5 and 7 of GADC; Paragraphs 1, 4 and 9 of Subsidiary Arrangement-PathwaysAustralian Embassy23rd Floor, Tower 2, RCBC Plaza6819 Ayala Ave.1200 Makati CityGentlemen :This refers to your letter dated 11 December 2017, which was indorsed by the Department of Foreign Affairs and received by this Office on 17 January 2018, requesting for Value-Added Tax (VAT) Exemption and/or Ruling on the purchase of goods and services for the Palladium International Pty. Ltd. (PIPL) relative to the implementation of Education Pathways to Peace in Mindanao (PATHWAYS) Program and the General Agreement on Development Cooperation between the Government of Australia and the Government of the Republic of the Philippines (GADC). HcSaADIt is represented that PIPL is the managing contractor of PATHWAYS Program on behalf of the Government of Australia (GOA); that the over-all goal of the nine-year PATHWAYS Program is to improve educational performance and equity in the attainment of quality basic education by children in the Autonomous Region in Muslim Mindanao (ARMM), contributing...