October 29, 2004
VAT RULING NO. 033-04
Sec. 27 (A), 108
VAT Ruling No. 051-01, 060-92
ITAD Ruling No. 009-03
Waagner-Biro Binder AG
c/o Waagner-Biro Philippines, Inc.
19/F-A Trafalgar Plaza
105 H. V. de la Costa Street
Salcedo Village, Makati City
Attention: Mr. Helmut J. Wuzela
President & CEO
Gentlemen :
This refers to your letter dated July 31, 2003 requesting for tax relief concerning your contract with the Department of Public Works and Highways (DPWH).
It is represented that Waagner-Biro Binder AG (Waagner, for short) is a corporation duly organized and existing under and by virtue of the laws of Austria; that on August 20, 2001 it entered into an agreement with the Government of the Republic of the Philippines, represented by the DPWH, for the design, fabrication, supply and other required services for Steel Truss Bridging Material in connection with the Austrian Assisted Bridge Construction/Replacement Project of the DPWH; that the design and fabrication of the bridging materials are undertaken in Austria (the OFFSHORE Portion) while the performance of local services (the ONSHORE Portion) under the Contract was assigned by Waagner to Waagner-Biro Philippines, Inc. (WBPI),...
