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November 16, 2018ITAD BIR RULING NO. 115-18Section 114 (C), National Internal Revenue Code of 1997, as amended;Revenue Memorandum Circular No. 8-2017Sycip Gorres Velayo and Co.6760 Ayala Avenue1226 Makati CityAttention: AAA_______________Gentlemen :This refers to your letters dated August 31 and February 7, 2017 requesting confirmation that the Department of Public Works and Highways ("DPWH") will no longer withhold the 5% final withholding value-added tax ("VAT") on its payments to Shimizu Corporation Manila Branch ("Shimizu Manila Branch") in light of the issuance of Revenue Memorandum Circular No. 8-2017 1 ("RMC 8-2017"). HTcADCAs a background, Shimizu Manila Branch is a Japanese contractor to the following projects of the DPWH which are funded under the Overseas Economic Cooperation Fund ("OECF") of Japan:1.  Civil Works for Arterial Road Bypass Project, Phase 2, Contract Package 3, Plaridel Bypass Road, located in the Province of Bulacan; and2.  Pasig-Marikina River Channel Improvement Project, Phase 3, Contract Package 1.In the discussion between DPWH and Shimizu Manila Branch, DPWH informed Shimizu Manila Branch that it will continue to withhold the 5% final VAT on its...