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September 20, 2005VAT RULING NO. 019-05Secs. 102 & 107, NIRC; RA Nos. 776, 7151, 7716 & 8241; P.D. 1590;BIR Ruling Nos. 3-95 & DA-219-97; RMC 6-96; R.R. 7-95 DA 219-97Romulo, Mabanta, Buenaventura Sayoc & De Los Angeles30th Floor, Citibank Tower8741 Paseo de RoxasMakati CityAttention: Attys. Perry L. Pe & Jayson L. FernandezGentlemen :This refers to your letter dated January 5, 2005 requesting on behalf of your client, Cebu Air, Inc. ("Cebu Pacific" for brevity), for confirmation that the importation of aircraft, aircraft equipment, engines, machinery, spare parts and accessories by Cebu Pacific is exempt from the value added tax ("VAT" for brevity) imposed under Section 107 of the National Internal Revenue Code of 1997 ("NIRC of 1997" for brevity). The facts, as you represent, are as follows:Cebu Pacific is a corporation organized and existing under the laws of the Republic of the Philippines. It is the holder of a legislative franchise granted under Republic Act No. 7151 to establish, operate and maintain transport services for the carriage of passengers, mail, goods and property by air,...