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May 4, 2005VAT RULING NO. 006-05Sec. 108 (B) (3) RA 7916 RMC 74-99 VAT Ruling 011-03F.F. Cruz & Co., Inc.800 E. de los Santos AvenueQuezon CityAttention: Mr. Felipe F. CruzPresidentGentlemen :This refers to your latter dated January 14, 2005 stating that you are about to sign a contract with the Philippine Associated Smelting and Refining Corporation (PASAR) for the renovation of its old pier plus additional lengths, for about P400 Million including VAT. You also submitted a copy of a certification by the Philippine Economic Zone Authority (PEZA) that PASAR is registered with the then Export Processing Zone Authority (EPZA), now PEZA, as a Zone Export Enterprise for the manufacture of copper cathodes, gold in dore, silver in dore, selenium blister copper (containing copper, gold and silver) and sulfuric acid. In addition, you also represented that you are a VAT-registered taxpayer. Based thereon, you now request for a ruling on the following:1. The VAT treatment of construction services to be rendered by your firm to PASAR; and2. Whether or not you can claim input tax...