February 9, 2010
VAT RULING NO. 003-10
RR 16-2005 & RMC 7-2006
Atty. Rolando P. Nonato
Tulips Center
A.S. Fortuna St.
Bakilid, Mandaue City
Sir :
This refers to your follow-up letter dated August 18, 2009 requesting on behalf of your client, Primary Industrial Properties Corporation ("PIPC"), for confirmation of your opinion that as lessor of information technology (IT) and industrial building spaces to PEZA-registered IT and export enterprises located inside the Mactan Ecozones I and II and in Asiatown IT Park, PIPC is exempt from the registration requirements of the provisions of Revenue Memorandum Order No. 7-2006. SaICcT
As represented, PIPC is a PEZA-registered zone service and facility enterprise and pays the 5% special tax rate under the provisions of the Special Economic Zone Act of 1995. As a zone service enterprise, it has been issued a Certificate of Registration No. 94-A10 and a Letter of Approval No. 05-1197 dated October 11, 2005 by the PEZA.
PIPC has entered into lease contracts with a number of PEZA zone export and IT locators/enterprises and as such lessor enjoying the 5% special tax rate, you allege...
