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October 23, 2018ITAD BIR RULING NO. 109-18Philippines-Australia General Agreement on Development CooperationPhilippine Business for Social Progress, Inc.Philippine Social Development CenterMagallanes St. corner Real St.Intramuros, Manila 1002Attention: AAA_______________Gentlemen :This refers to your letter dated November 13, 2014 requesting confirmation that purchases of program supplies, vehicles, professional and technical materials and services made by the Philippine Business for Social Progress, Inc. (PBSP) pursuant to the Subsidiary Arrangement between the Government of the Philippines (GOP) and the Government of Australia (GOA) for the implementation of the Best Education Sector Transformation (BEST) Program are subject to exemption/zero percent value-added tax ("VAT") pursuant to the Philippines-Australia General Agreement on Development Cooperation ("GADC").It is represented that the GOP and GOA signed GADC on the 28th of October 1994 in Sydney, Australia, to strengthen the existing cordial relations between the two governments and to foster development cooperation between the Philippines and Australia. Under the GADC, the GOP and GOA or their agencies, statutory authorities or organizations may conclude subsidiary arrangements in respect of specific activities. HTcADCIt is further represented that pursuant to...