March 7, 2008

VAT RULING NO. 001-08

RR 11-00; 237

Ong, Ordoñez & Associates
8F 111 Paseo de Roxas Bldg.
Paseo de Roxas cor. Legazpi Street
Legazpi Vill., Makati City

Attention: Ms. Catherine M. Saldi

Gentlemen :

This refers to your letter dated May 31, 2006 requesting for a ruling which will allow your client, INCO7 Inc., to use/issue purchase invoices to peddlers as evidence/supporting documents to their transaction.

It is represented that the business of INCO7 Inc. is related to manufacturing and trading of metal products; that it is duly registered with the Securities and Exchange Commission under SEC Registration No. CS200514460, dated August 24, 2005; that its primary purpose is to engage in the business of import/export/trading of goods such as metal scrap, waste, junk and general merchandise on wholesale/retail basis; that most of its suppliers are peddlers or those who sell goods on carts (wheeled wagons); or those called peddlers; and that most of these peddlers are marginal income earners and are not registered with the Bureau of Internal Revenue and that they do not issue any registered invoice in their sales...

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