n\a

November 3, 2006VAT RULING NO. 011-06R.A. 9337Philippine Ports AuthorityMarsman Building, 22 Muelle De San FranciscoSouth Harbor, Port AreaManila 1018Attention: Ms. Aida P. DizonAssistant General ManagerFinance & AdministrationGentlemen :This is to clarify the value-added tax (VAT) liability of the Philippine Ports Authority (PPA) on its various transactions. It is represented that PPA is a government-owned or controlled corporation and a VAT-registered taxpayer; that as such, all its fees and charges covering its sale of services and use or lease of properties are subject to VAT, and which it may legally shift to its port-users or customers and remit the same to this Bureau; and that several issues were raised by the clientele/customers of PPA in the imposition of VAT on their respective transactions.In reply, please be informed as follows:It is clear from Revenue Memorandum Circular No. 2-2004 1 under the heading, "VAT Liability of the Philippine Port Authority", all fees and charges collected by the PPA such as, but not limited to the following, are subject to VAT:1. Port Dues (Harbor fees)/Anchorage fees2. Dockage-Berthing Income3. Usage...