April 11, 2005
VAT RULING NO. 004-05
P.D. 1869, R.A.s 7716, 8424, Sec 27 NIRC VAT Rulings 004-96, 138-98, 030-99, 113-99, 041-01
Villanueva, Villanueva & Associates CPAs
Tax Consultancy Services
Km. 19 J.P. Rizal Avenue, Concepcion I
1807, Marikina City, Philippines
Attention: Mr. Felix Perry A. Villanueva
Managing Partner
Gentlemen :
This refers to your undated letter which we received last July 20, 2004 written for and in behalf of your client, Technology Support Services, Inc. (formerly First Advance Multimedia Entertainment, Inc.), TSSI-FAME for short, seeking answers to the following queries:
1. Is TSSI-FAME subject to the payment of franchise tax on gross sales and/or income taxes on its net income?
2. Is the sale of the gaming pre-paid cards or "Electronic Playing Chips" so-called by the PAGCOR-authorized-and-approved Agents in connection with the operation of nationwide Internet-based and mobile-based games subject to the value-added tax?
3. Is the purchase of goods and/or services by TSSI-FAME subject to the value-added tax? and
4. Are those receiving compensation or other remuneration from the Corporation or operator as a result of essential facilities furnished and/or technical services rendered to the Corporation...
