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August 8, 2005VAT RULING NO. 011-05Sec. 8, R.A. 9136 Sec. 6 (b)Hydro Electric Development Corporation110 Legaspi Street, Legaspi VillageMakati, Metro ManilaAttention: Mr. Jose Venancio P. BatiguinManaging DirectorGentlemen :This refers to your letter dated November 7, 2003 requesting for a ruling to the effect that the "sales of generated power by generation companies shall be value added tax zero-rated" pursuant to Chapter II Section 6 paragraph 5 of Republic Act (R.A.) No. 9136 (EPIRA); and such sales of generated power by said generation companies is subject to value added tax at zero percent from the effectivity of the EPIRA. FACTUAL BACKGROUNDHydro Electric Development Corporation (HEDCOR for brevity) is a corporation duly organized and existing under and by virtue of the laws of the Republic of the Philippines with office address at 214 Obulan, Beckel, La Trinidad, Benguet. HEDCOR is engaged in the business of developing potential sites for hydroelectric power in the Province of Benguet and Baguio City. It has been registered as such pursuant to Republic Act No. 7156 otherwise known as "An Act Granting...