March 19, 2008

VAT RULING NO. 002-08

Sec. 109 (R), R.A. 9337, Secs. 5 (f) & 7, R.A. 8792; VAT Ruling No. 047-2003

CE-Logic Inc.
1672 Quezon Avenue, South Triangle
Quezon City

Attention: Franklin A. Naig
Legal Counsel

Gentlemen :

This refers to your letter dated October 3, 2007, requesting for a ruling that sales of educational products in digital/electronic format is not subject to VAT.

It is represented that CE-Logic, Inc. (CE-Logic), is a corporation organized under Philippine laws with office address at 1672 Quezon Avenue, South Triangle, Quezon City; and that it is primarily engaged in the business of selling educational products, mainly acting as the exclusive distributor in the Philippines of online academic library resources, e-Books, and e-Journals of various foreign publishers. The products that CE-Logic sells, are described as follows:

1. ONLINE ACADEMIC LIBRARY RESOURCES — An online library resource is a library in which collections are stored in digital formats (as opposed to print, microform, or other media) and accessible by computer. The digital content may be stored locally, or accessed remotely via the internet or computer networks.

2. E-BOOKS...

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