Value-Added Tax – (Secs. 105 to 115 of the NIRC as amended by RA 10963)

  • Value-Added Tax – (Secs. 105 to 115 of the NIRC as amended by RA 10963)
    • VAT In General
      • Nature and characteristic of VAT in general
        • Sec. 4.105.-2 of RR No. 16-05 Nature and Characteristics of VAT. – VAT is a tax on consumption levied on the sale, barter, exchange or lease of goods or properties and services in the Philippines and on importation of goods into the Philippines. The seller is the one statutorily liable for the payment of the tax but the amount of the tax may be shifted or passed on to the buyer, transferee or lessee of the goods, properties or services. This rule shall likewise apply to existing contracts of sale or lease of goods, properties or services at the time of the effectivity of RA No. 9337. However, in the case of importation, the importer is the one liable for the VAT.
        • CIR vs. Magsaysay LinesGR No. 146984, July 28, 2006
          • The conclusion that the sale was not in the course of trade or business, which the CIR does not dispute before this Court, should have definitively settled the matter. Any sale, barter or exchange of goods or services not in the course of trade or business is not subject to VAT. Accordingly, the Court rules that given the undisputed finding that the transaction in question was not made in the course of trade or business of the seller, NDC that is, the sale is not subject to VAT pursuant to Section 99 of the Tax Code, no matter how the said sale may hew to those transactions deemed sale as defined under Section 100.
        • CIR vs. Seagate Technology (Phils) – GR No. 153866 February 11, 2005
          • Business companies registered in and operating from the Special Economic Zone in Naga, Cebu — like herein respondent — are entities exempt from all internal revenue taxes and the implementing rules relevant thereto, including the value-added taxes or VAT. Although export sales are not deemed exempt transactions, they are nonetheless zero-rated. Hence, in the present case, the distinction between exempt entities and exempt transactions has little significance, because the net result is that the taxpayer is not liable for the VAT. Respondent, a VAT-registered enterprise, has complied with all requisites for claiming a tax refund of or credit for the input VAT it paid on capital goods it purchased. Thus, the Court of Tax Appeals and the Court of Appeals did not err in ruling that it is entitled to such refund or credit.
      • VAT as an indirect tax
      • Persons Liable (Sec. 105)
        • Persons liable in general
          CIR vs. COURT OF APPEALS and COMMONWEALTH MANAGEMENT AND SERVICES CORPORATION (COMASERCO) – GR No. 125355, March 30, 2000
        • Who are required to register for VAT
          • Sec. 236(G), [Sec. 9.236-1 of RR No. 16-05]
          • Sec. 236(H)
        • Optional VAT Registration (Sec. 236 H) [Sec. 9.236-1 of RR No. 16-05]
        • Meaning of the phrase “in the course of trade of business” (Sec. 105)
          • Sec. 4.105-3 of RR No. 16-05
            • CIR vs. Magsaysay Lines GR No. 146984 dated July 28, 2006
            • Mindanao II Geothermal Partnership vs. CIR GR No. 193301 dated March 11,2013
            • CIR vs. Sony Philippines, Inc. G.R. No. 178697, November 17, 2010
            • Power Sector Assets and Liabilities Management Corporation (PSALM) vs. CIR, GR No. 198146 dated August 8, 2017
          • Exceptions to the Rule of Regularity
          • Output Tax vs. Input Taxes
            • Sources of Input Tax (Sec. 110 A)
            • Excess Output or Input Tax (Sec. 110 B):
            • Rule on Input Tax on Capital Goods (Sec. 4.110-3 of RR No. 16-05)
              1. Sec. 4.110-3 of RR No. 16-05 as amended by Sec. 16 of RR 4-2007
              2. Sec. 4.110-3 of RR No. 13-2018
              TRAIN AMENDMENT
              d. Substantiation of Input Tax Credits (Sec. 4.110-8 of RR No. 16-05)
              CIR vs. Sony Philippines, Inc. G.R. No. 178697, November 17, 2010
              Section 113 and 237
              Sec. 4.110-8 of RR No. 16-05
              Sec. 4-113-1(B) of RR No. 16-05
              II. Vatable Transactions
              1. Vatable Sale on Goods & Services
              a. Definition of goods and services (Sec. 106 and Sec. 108)
              Real Properties (Sec. 4.106-4 of RR No. 16-05)
              b. VAT base for goods and services
              Sec. 106 and Sec.108
              Sec. 4.106-9 of RR No. 16-05
              Sec. 4.108-4 of RR No. 16-05, as amended by RR No. 4-07
              c. Meaning of gross selling price and gross receipts (Sec. 106 and Sec.108)
              Sec. 11 of RR No. 4-07
              Medicard Philippines, Inc. vs. CIR – GR No. 222743 dated April 5, 2017
            • As to the CIR’s argument that the act of earmarking or allocation is by itself an act of ownership and management over the funds, the Court does not agree. On the contrary, it is MEDICARD’s act of earmarking or allocating 80% of the amount it received as membership fee at the time of payment that weakens the ownership imputed to it. By earmarking or allocating 80% of the amount, MEDICARD unequivocally recognizes that its possession of the funds is not in the concept of owner but as a mere administrator of the same. For this reason, at most, MEDICARD’s right in relation to these amounts is a mere inchoate owner which would ripen into actual ownership if, and only if, there is underutilization of the membership fees at the end of the fiscal year. Prior to that, MEDI CARD is bound to pay from the amounts it had allocated as an administrator once its members avail of the medical services of MEDICARD’s healthcare providers.
              d. Rules on sales of Real Property
              (1) Rule on Sales on Instalment [RR No. Sec. 4.106-3 of RR No. 16-05 as amended by Sec. 3 of RR No. 4-07] (2) Rule on sale of real property used in business
              Sec. 14 (l) of RR No. 4-07
              (3) Correlate with Sec. 109 on exempt sales of Real Property
              Sec. 4.109-1(p)(1) of RR No. 16-05, as amended by RR No. 4-07 and RR No. 13-18)
              Sale of Parking Lot (Sec. 4.109-1(p)(4), RR No. 16-05, as amended by RR No. 13-2012)
              Sale of Adjacent lands (RR No 13-2012)
              e. Transactions deemed sale (Sec. 106 B)
              (1) Rationale of Imposition
              (2) Enumeration
              Sec. 4.106-7 RR No. 16-05
              Sec. 106(B), NIRC
              Sec. 4.106-8(a), RR No. 16-05
              Sec. 4.106-8 (b), RR No. 16-05
              (3) Tax Base of Transactions Deemed Sale
              Sec. 4.106-7 (b), RR No. 16-05
              f. Rules for Certain Services
              (1) Common Carriers
              Secs. 108, 109(S) 116, 117 and 118 (as amended by RA 10963)
              Sec. 4.108-2 Nos. 11 and 12 of RR No. 16-05
              Sec. 4.108-3 of RR No. 16-05
              (2) Lease of Properties
              Sec. 4.108-3 of RR No. 16-05
              Lease of Residential Units – [Sec. 4.109-1(B)(q) of RR No. 16-05]
              Amendments of Section 109 on Enumerated VAT-exempt Transactions under Rep. Act No. 10963 (TRAIN) on Threshold of Lease of Residential Units exempt from VAT. (RR No. 13-18)
              (3) Professional Services
              RMC No. 89-2012
              RMC No. 16-2013
              (4) Medical Services
              Sec. 4.109-1 (B)(g) of RR No. 16-05
              Philippine Healthcare Providers vs. CIR GR No. 168129 April 24, 2007
              (5) Cinema Operators /Proprietors
              CIR vs. SM Prime Holdings, GR No. 183505 dated February 26, 2010
            • These reveal the legislative intent not to impose VAT on persons already covered by the amusement tax. This holds true even in the case of cinema/theater operators taxed under the LGC of 1991 precisely because the VAT law was intended to replace the percentage tax on certain services. The mere fact that they are taxed by the local government unit and not by the national government is immaterial. The Local Tax Code, in transferring the power to tax gross receipts derived by cinema/theater operators or proprietor from admission tickets to the local government, did not intend to treat cinema/theater houses as a separate class. No distinction must, therefore, be made between the places of amusement taxed by the national government and those taxed by the local government.To hold otherwise would impose an unreasonable burden on cinema/theater houses operators or proprietors, who would be paying an additional 10%55 VAT on top of the 30% amusement tax imposed by Section 140 of the LGC of 1991, or a total of 40% tax. Such imposition would result in injustice, as persons taxed under the NIRC of 1997 would be in a better position than those taxed under the LGC of 1991. We need not belabor that a literal application of a law must be rejected if it will operate unjustly or lead to absurd results.56 Thus, we are convinced that the legislature never intended to include cinema/theater operators or proprietors in the coverage of VAT.(6) VAT on Toll Fees
              Diaz vs. the SOF and the CIR, GR No. 193007 dated July 19, 2011
              (7) Franchise Grantees
              Sec. 4.108-3(h), RR No. 16-05
              PAGCOR vs. BIR; GR No. 172087; March 15, 2011
              2. VAT on Importations
              a. VAT Imposition on Importation (Sec. 107)
              b. Exempt Importations under Sec. 109, as amended by RA No. 10863
              c. Transfer of Goods by Tax-exempt Persons (Sec. 107 B)
              d. Amendments of Section 109 on Enumerated VAT-exempt Transactions under Rep. Act No. 10963 (TRAIN)
              III. Zero-rated Sales & VAT-exempt Transactions
              1. Nature of Zero Rated Sales – [The following sales by VAT-registered persons shall be subject to zero percent (0%) rate:

              (a) Export Sales. – The term ‘export sales’ means:

              (1) The sale and actual shipment of goods from the Philippines to a foreign country, irrespective of any shipping arrangement that may be agreed upon which may influence or determine the transfer of ownership of the goods so exported and paid for in acceptable foreign currency or its equivalent in goods or services, and accounted for in accordance with the rules and regulations of the Bangko Sentral ng Pilipinas (BSP);

              (2) Sale of raw materials or packaging materials to a nonresident buyer for delivery to a resident local export-oriented enterprise to be used in manufacturing, processing, packing or repacking in the Philippines of the said buyer’s goods and paid for in acceptable foreign currency and accounted for in accordance with the rules and regulations of the Bangko Sentral ng Pilipinas (BSP);

              (3) Sale of raw materials or packaging materials to export-oriented enterprise whose export sales exceed seventy percent (70%) of total annual production;

              (4) Sale of gold to the Bangko Sentral ng Pilipinas (BSP); and

              (5) Those considered export sales under Executive Order NO. 226, otherwise known as the Omnibus Investment Code of 1987, and other special laws.

              (b) Foreign Currency Denominated Sale. – The phrase ‘foreign currency denominated sale’ means sale to a nonresident of goods, except those mentioned in Sections 149 and 150, assembled or manufactured in the Philippines for delivery to a resident in the Philippines, paid for in acceptable foreign currency and accounted for in accordance with the rules and regulations of the Bangko Sentral ng Pilipinas (BSP).

              (c) Sales to persons or entities whose exemption under special laws or international agreements to which the Philippines is a signatory effectively subjects such sales to zero rate.]

              2. Zero Rated Sale of Goods (Sec. 106) (See Sec 2 RR 13-2018 amending Sec 4.106-5 of RR 16-2005, as further amended by the TRAIN LAW)
              3. Zero Rated Sale of Services (Sec. 108 B) (See Sec 2 RR 13-2018 amending Sec 4.108-5 of RR 16-2005)

            • CIR vs. American Express GR No. 152609 dated June 29, 2005 – [As a general rule, the value-added tax (VAT) system uses the destination principle. However, our VAT law itself provides for a clear exception, under which the supply of service shall be zero-rated when the following requirements are met: (1) the service is performed in the Philippines; (2) the service falls under any of the categories provided in Section 102(b) of the Tax Code; and (3) it is paid for in acceptable foreign currency that is accounted for in accordance with the regulations of the Bangko Sentral ng Pilipinas. Since respondent’s services meet these requirements, they are zero-rated.]
            • CIR vs. BURMEISTER AND WAIN SCANDINAVIAN CONTRACTOR MINDANAO, INC. GR No. 153205 dated Jaunary22, 2007 – [The Tax Code not only requires that the services be other than “processing, manufacturing or repacking of goods” and that payment for such services be in acceptable foreign currency accounted for in accordance with BSP rules. Another essential condition for qualification to zero-rating under Section 102(b)(2) is that the recipient of such services is doing business outside the Philippines. While this requirement is not expressly stated in the second paragraph of Section 102(b), this is clearly provided in the first paragraph of Section 102(b) where the listed services must be “for other persons doing business outside the Philippines.” The phrase “for other persons doing business outside the Philippines” not only refers to the services enumerated in the first paragraph of Section 102(b), but also pertains to the general term “services” appearing in the second paragraph of Section 102(b). In short, services other than processing, manufacturing, or repacking of goods must likewise be performed for persons doing business outside the Philippines.]
            • CIR vs. Acesite (PH) Hotel Corporation GR No. 147295 dated February 16, 2007 – [Indeed, by extending the exemption to entities or individuals dealing with PAGCOR, the legislature clearly granted exemption also from indirect taxes. It must be noted that the indirect tax of VAT, as in the instant case, can be shifted or passed to the buyer, transferee, or lessee of the goods, properties, or services subject to VAT. Thus, by extending the tax exemption to entities or individuals dealing with PAGCOR in casino operations, it is exempting PAGCOR from being liable to indirect taxes.]
              a. Automatic zero-rate vs. Effectively zero-rate
              CIR vs. Seagate Technology (Phils) GR No. 153866 February 11, 2005 – [Business companies registered in and operating from the Special Economic Zone are entities exempt from all internal revenue taxes and the implementing rules relevant thereto, including the value-added taxes or VAT. Although export sales are not deemed exempt transactions, they are nonetheless zero-rated.]
              CIR vs. Toshiba Information Equipment (Phils) Inc. GR No. 150154 dated August 9, 2005 – []
              b. Destination principle and cross border doctrine
              CIR vs. American Express GR No. 152609 dated June 29, 2005
              CIR vs. Toshiba Information Equipment GR No. 150154 dated August 9, 2005
              c. Zero Rated Sales vs. Exempt Sales
              CIR vs. Cebu Toyo Corp. GR No. 149073 dated February 16, 2005
              d. Enumeration of Exempt Transactions (Sec. 109)
              Sec. 4.109-1 (B) of RR No. 16-05 as amended by RR 13-2018
              e. Exempt Persons vs. Exempt Transactions
              CIR vs. Seagate Technology (Phils) GR No. 153866 February 11, 2005
              f. Amendments under Rep. Act No. 10378
              g. Amendments of Section 106 on Enumerated Export Sales under Rep. Act No. 10963 (TRAIN) & the Vetoed Provisions h. Amendments of Section 108 on Enumerated Zero-Rated Services under Rep. Act No. 10963 (TRAIN) & the Vetoed Provisions i. Amendments of Section 109 on Enumerated VAT-exempt Transactions under Rep. Act No. 10963 (TRAIN)
              IV. Transitional & Presumptive Input Taxes
              Sec. 111 of the NIRC
              Sec. 4.111-1 of RR No. 16-05
              Fort Bonifacio Development Corporation vs. CIR GR No. 158885 dated April 2, 2009
              V. VAT Claim for Refund
              Sec. 112(A) of the NIRC – [(A) Zero-rated or Effectively Zero-rated Sales. – any VAT-registered person, whose sales are zero-rated or effectively zero-rated may, within two (2) years after the close of the taxable quarter when the sales were made, apply for the issuance of a tax credit certificate or refund of creditable input tax due or paid attributable to such sales, except transitional input tax, to the extent that such input tax has not been applied against output tax: Provided, however, That in the case of zero-rated sales under Section 106(A)(2)(a)(1), (2) and (B) and Section 108 (B)(1) and (2), the acceptable foreign currency exchange proceeds thereof had been duly accounted for in accordance with the rules and regulations of the Bangko Sentral ng Pilipinas (BSP): Provided, further, That where the taxpayer is engaged in zero-rated or effectively zero-rated sale and also in taxable or exempt sale of goods of properties or services, and the amount of creditable input tax due or paid cannot be directly and entirely attributed to any one of the transactions, it shall be allocated proportionately on the basis of the volume of sales.

              (B) Capital Goods. – A VAT-registered person may apply for the issuance of a tax credit certificate or refund of input taxes paid on capital goods imported or locally purchased, to the extent that such input taxes have not been applied against output taxes. The application may be made only within two (2) years after the close of the taxable quarter when the importation or purchase was made.

              (C) Cancellation of VAT Registration. – A person whose registration has been cancelled due to retirement from or cessation of business, or due to changes in or cessation of status under Section 106(C) of this Code may, within two (2) years from the date of cancellation, apply for the issuance of a tax credit certificate for any unused input tax which may be used in payment of his other internal revenue taxes.

              (D) Period within which Refund or Tax Credit of Input Taxes shall be Made. – In proper cases, the Commissioner shall grant a refund or issue the tax credit certificate for creditable input taxes within one hundred twenty (120) days from the date of submission of compete documents in support of the application filed in accordance with Subsections (A) and (B) hereof.

              In case of full or partial denial of the claim for tax refund or tax credit, or the failure on the part of the Commissioner to act on the application within the period prescribed above, the taxpayer affected may, within thirty (30) days from the receipt of the decision denying the claim or after the expiration of the one hundred twenty day-period, appeal the decision or the unacted claim with the Court of Tax Appeals.-

              (E) Manner of Giving Refund. – Refunds shall be made upon warrants drawn by the Commissioner or by his duly authorized representative without the necessity of being countersigned by the Chairman, Commission on audit, the provisions of the Administrative Code of 1987 to the contrary notwithstanding: Provided, That refunds under this paragraph shall be subject to post audit by the Commission on Audit.]

              1. Compare with Sec. 204 and 229 – [Section 204. Authority of the Commissioner to Compromise, Abate and Refund or Credit Taxes. – The Commissioner may –

              (A) Compromise the payment of any internal revenue tax, when:

              (1) A reasonable doubt as to the validity of the claim against the taxpayer exists; or

              (2) The financial position of the taxpayer demonstrates a clear inability to pay the assessed tax.

              The compromise settlement of any tax liability shall be subject to the following minimum amounts:

              For cases of financial incapacity, a minimum compromise rate equivalent to ten percent (10%) of the basic assessed tax; and

              For other cases, a minimum compromise rate equivalent to forty percent (40%) of the basic assessed tax.

              Where the basic tax involved exceeds One million pesos (P1,000.000) or where the settlement offered is less than the prescribed minimum rates, the compromise shall be subject to the approval of the Evaluation Board which shall be composed of the Commissioner and the four (4) Deputy Commissioners.

              (B) Abate or cancel a tax liability, when:

              (1) The tax or any portion thereof appears to be unjustly or excessively assessed; or

              (2) The administration and collection costs involved do not justify the collection of the amount due.

              All criminal violations may be compromised except: (a) those already filed in court, or (b) those involving fraud.

              (C) Credit or refund taxes erroneously or illegally received or penalties imposed without authority, refund the value of internal revenue stamps when they are returned in good condition by the purchaser, and, in his discretion, redeem or change unused stamps that have been rendered unfit for use and refund their value upon proof of destruction. No credit or refund of taxes or penalties shall be allowed unless the taxpayer files in writing with the Commissioner a claim for credit or refund within two (2) years after the payment of the tax or penalty: Provided, however, That a return filed showing an overpayment shall be considered as a written claim for credit or refund.

              A Tax Credit Certificate validly issued under the provisions of this Code may be applied against any internal revenue tax, excluding withholding taxes, for which the taxpayer is directly liable. Any request for conversion into refund of unutilized tax credits may be allowed, subject to the provisions of Section 230 of this Code: Provided, That the original copy of the Tax Credit Certificate showing a creditable balance is surrendered to the appropriate revenue officer for verification and cancellation: Provided, further, That in no case shall a tax refund be given resulting from availment of incentives granted pursuant to special laws for which no actual payment was made.

              The Commissioner shall submit to the Chairmen of the Committee on Ways and Means of both the Senate and House of Representatives, every six (6) months, a report on the exercise of his powers under this Section, stating therein the following facts and information, among others: names and addresses of taxpayers whose cases have been the subject of abatement or compromise; amount involved; amount compromised or abated; and reasons for the exercise of power: Provided, That the said report shall be presented to the Oversight Committee in Congress that shall be constituted to determine that said powers are reasonably exercised and that the government is not unduly deprived of revenues.] VS [Section 229. Recovery of Tax Erroneously or Illegally Collected. – no suit or proceeding shall be maintained in any court for the recovery of any national internal revenue tax hereafter alleged to have been erroneously or illegally assessed or collected, or of any penalty claimed to have been collected without authority, of any sum alleged to have been excessively or in any manner wrongfully collected without authority, or of any sum alleged to have been excessively or in any manner wrongfully collected, until a claim for refund or credit has been duly filed with the Commissioner; but such suit or proceeding may be maintained, whether or not such tax, penalty, or sum has been paid under protest or duress.

              In any case, no such suit or proceeding shall be filed after the expiration of two (2) years from the date of payment of the tax or penalty regardless of any supervening cause that may arise after payment: Provided, however, That the Commissioner may, even without a written claim therefor, refund or credit any tax, where on the face of the return upon which payment was made, such payment appears clearly to have been erroneously paid.]

              2. Grounds
              3. Periods
              Sec. 112 of the NIRC (as amended by RA 10963) 
              RMC No. 17-2018 – [Sec. 112. Refunds or Tax Credits of Input Tax -(C) Period within which Refund of Input Taxes shall be Made.— In proper cases, the Commissioner shall grant a refund for creditable input taxes within ninety (90) days from the date of submission of the official receipts or invoices and other documents in support of the application filed in accordance with Subsections (A) and (B) hereof: Provided, That should the Commissioner find that the grant of refund is not proper, the Commissioner must state in writing the legal and factual basis for the denial.”In case of full or partial denial of the claim for tax refund, the taxpayer affected may, within thirty (30) days from the receipt of the decision denying the claim, appeal the decision with the Court of Tax Appeals: Provided, however, That failure on the part of any official, agent, or employee of the BIR to act on the application within the ninety (90)-day period shall be punishable under Section 269 of this Code.]

              Contex vs. CIR GR No. 151135 dated July 2, 2004 – [in indirect taxation, there is a need to distinguish between the liability for the tax and the burden of the tax. As earlier pointed out, the amount of tax paid may be shifted or passed on by the seller to the buyer. What is transferred in such instances is not the liability for the tax, but the tax burden. In adding or including the VAT due to the selling price, the seller remains the person primarily and legally liable for the payment of the tax. What is shifted only to the intermediate buyer and ultimately to the final purchaser is the burden of the tax. Stated differently, a seller who is directly and legally liable for payment of an indirect tax, such as the VAT on goods or services is not necessarily the person who ultimately bears the burden of the same tax. It is the final purchaser or consumer of such goods or services who, although not directly and legally liable for the payment thereof, ultimately bears the burden of the tax.]
              Atlas Consolidated Mining vs. CIR GR Nos. 141104 and 148763 June 8, 2007
              CIR vs. Mirant Pagbilao Corp GR No. 172129 dated September 12, 2008
              2
              CIR vs. SAN ROQUE POWER GR No. 187485 dated February 12, 2013
              4. Amendments of Section 112 under Rep. Act No. 10963 (TRAIN) on Change of Period from 120 to 90 days and No Inaction Provisions and Penalties for BIR Inaction. (See Sec 2 RR 13-2018 amending Sec 4.112-1 of RR 16-2005)
              VI. Other Matters
              1. Invoicing Requirements
              (Sec. 113) [Sec. 4.1113-1 of RR No. 16-05]
              Microsoft Phils., Inc. vs. CIR, GR No. 180173 dated April 6, 2011
              Coca-Cola Bottlers Philippines, Inc. vs. CIR, GR No. 222428 dated February 19, 2018
              Silicon Phils., Inc. vs. CIR, GR No. 172378 dated January 17, 2011
              2. Information which must be contained (Sec. 113)
              3. Consequences of Issuing Erroneous VAT Invoice
              (Sec. 113) [ RR No. 4.113-4 of RR No. 16-05]
              4. Filing of Monthly and Quarterly VAT Returns and Payment of VAT (Sec. 114)
              Amendment of the TRAIN Law
              5. Summary Lists of Sales and Purchases (RR No. 1-2012)
              6. Amendments of Section 114 under Rep. Act No. 10963 (TRAIN) on Changes in Filing to Quarterly Filing of VAT Return (See Sec 2 RR 13-2018 amending Sec 4.114-1 of RR 16-2005)
              7. Withholding VAT (Sec. 114 C) [Sec. 4.114-2 of RR No. 16-05 as amended by Sec. 22 of RR No. 4-07 and RR 13-2018] (1) Government payments
              (2) Amendments of Section 114 under Rep. Act No. 10963 (TRAIN) on Change from Final Withholding VAT to Creditable Withholding VAT on Government Payments
              (3) Services Rendered by Non-residents
              (4) Withholding VAT Returns/Time of Payment
              (5) Power of the Commissioner to Suspend Business Operations (Sec.5) [Sec. 4.115-1 of RR No. 16-05]

One thought on “Value-Added Tax – (Secs. 105 to 115 of the NIRC as amended by RA 10963)

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