Title
VAT System Restructuring and Administration
Law
Republic Act No. 7716
Decision Date
May 5, 1994
Republic Act No. 7716 restructures the value-added tax (VAT) system by broadening its tax base, enhancing administration, and establishing a 10% VAT on goods and services while outlining exemptions and zero-rated transactions to promote economic activity.

VAT on Sale of Goods or Properties

  • VAT rate fixed at 10% of gross selling price or gross value of goods or properties sold, bartered, or exchanged.
  • "Goods or properties" include tangible/intangible objects like real properties held for sale or lease, rights to use patents, trademarks, equipment, films, and broadcast time.
  • Gross selling price excludes VAT but includes any excise tax.
  • Zero-rated sales include export sales, foreign currency-denominated sales, and sales to exempt persons/entities under special laws or international agreements.
  • Certain transactions such as use or consumption outside business, distribution to shareholders, consignment without sale after 60 days, or business cessation inventories are deemed sales.
  • Tax is computed by multiplying the invoice amount by 1/11.
  • Sales returns, allowances, and discounts can reduce the gross sales for tax purposes.

VAT on Sale of Services and Use or Lease of Properties

  • A 10% VAT imposed on gross receipts from sales or exchanges of services and leases.
  • "Sale or exchange of services" covers a broad range including construction, brokerage, leasing, hospitality, finance, insurance, and other professional and commercial services.
  • Gross receipts exclude VAT and include fees, rentals, royalties, and advances received.
  • Zero-rated services include processing/manufacturing for export, services paid in foreign currency, services to exempt persons/entities, services to international vessels, and subcontracted services relating to high-export enterprises.
  • Tax computation similarly uses the 1/11 multiplier on official receipts.

VAT-Exempt Transactions

  • Exemptions include sales of nonfood agricultural, marine, and forest products in original state by primary producers.
  • Exempt also include sale/import of cotton, copra, fertilizers, seeds, animal feeds, and certain petroleum products.
  • Importation exemptions for certain vessels, personal effects of returning residents/nonresident citizens, and professional instruments.
  • Services subject to percentage tax, certain agricultural processing, medical, educational, employee services, artists' sales, and services by multinational headquarters are exempt.
  • Real properties not held primarily for sale or lease and low-cost housing sales also exempt.
  • Small business with gross sales below prescribed thresholds pay percentage tax instead.
  • Issuing VAT invoices or receipts on exempt transactions triggers VAT liability without credit.

Tax Credits

  • Input tax (VAT on purchases/imports) creditable against output VAT includes:
    • Goods for sale or as materials/supplies in business or services;
    • Services with VAT paid.
  • Input tax is creditable upon sale consummation or payment.
  • VAT-registered persons conducting exempt and non-exempt transactions allocate input tax based on usage.
  • Excess input tax carried over, with option to claim refund or apply credit for capital goods or zero-rated sales input taxes.

Refunds or Tax Credits of Creditable Input Tax

  • VAT-registered persons with zero-rated or effectively zero-rated sales may apply for tax credit or refunds within two years.
  • Requirements include foreign currency proceeds accounting compliance.
  • Input taxes on capital goods also refundable or creditable within two years.
  • Cancellation of VAT registration allows claiming unused input tax within two years.
  • Commissioner to grant refunds or credits within 60 days; denial or inaction appealable to Court of Tax Appeals.
  • Refunds issued without need for Commission on Audit countersignature but subject to post audit.

Registration of Value-Added Taxpayers

  • Persons liable for VAT must register with Revenue District Officer, paying P1,000 annual fee per establishment.
  • New businesses expecting taxable sales over exemption threshold must register 30 days prior.
  • Persons exceeding exemption threshold register within 30 days after period end and liable for VAT starting next month.
  • Optional registration available for exempt persons wishing to be VAT-registered.
  • Commissioner can deny registration for administrative reasons.
  • One TIN per VAT-registered person.
  • Registration cancellation upon cessation or status change.

Invoicing and Accounting Requirements for VAT-Registered Persons

  • Must issue invoice or receipt for every sale.
  • Invoice must state VAT registration and taxpayer identification number (TIN).
  • Invoice to specify total amount including VAT.
  • Maintain subsidiary sales and purchase journals with daily recordings.
  • Additional accounting details as prescribed by the Secretary of Finance.

Withholding of Creditable VAT by Government Entities

  • Government and its agencies to withhold 3% VAT on gross purchases of goods and 6% on services rendered by contractors.
  • Withholding on lease or use payments to nonresident owners is 10%.
  • Withheld VAT creditable against seller or contractor's VAT liability.

Tax on Persons Exempt from VAT

  • Non-VAT-registered persons exempt from VAT pay percentage tax: 3% on gross quarterly sales initially, increasing to 4% after two years.

Percentage Tax on Carriers and Keepers of Garages

  • Keepers of garages and common carriers (except bancas and animal-drawn two-wheelers) pay 3% quarterly tax on gross receipts.
  • Minimum quarterly gross receipts thresholds set by vehicle type and locale.
  • Income from freight services exempt from local taxes under the Local Government Code.

Tax on Franchises for Electric, Gas, and Water Utilities

  • 2% tax on gross receipts from businesses under franchise granted by law.
  • Returns filed with and taxes paid to the Commissioner of Internal Revenue.
  • Returns subject to BIR audit.

Tax on Life Insurance Premiums

  • 5% tax on total premiums collected by life insurance businesses (excluding cooperatives).
  • Exemptions for refunded premiums, reinsurance already taxed, and foreign insurance with reciprocal tax.
  • Variable contract premiums taxed only on amounts necessary to insure lives.

Taxpayer Identification Number (TIN) Requirements

  • TIN must be assigned and indicated on tax returns, statements, or documents.
  • Criminal liability for securing multiple TINs or failure to indicate correct TIN.

Registration of Business Name or Style

  • Persons not required to register under VAT must register name or style within 10 days of business start or transfer.
  • Annual fee P1,000 per business location.
  • Commissioner may require guarantee or security based on financial condition and sales volume.

Issuance of Receipts or Sales/Commercial Invoices

  • Receipts/invoices required for sales or services valued at P25 or more.
  • For sales P100 or more or VAT transactions, invoices must include buyer info and TIN if applicable.
  • Original receipt given to buyer; duplicate retained by issuer for 3 years.
  • Commissioner may exempt persons in meritorious cases.

Effectivity of VAT on Certain Services

  • VAT coverage extended after two years from enactment to include professional services, certain entertainers, broadcasters, financial intermediaries, international cargo freight, and lease/use of sports facilities.
  • President may exclude services for public interest with Secretary of Finance recommendation.

Tax Administration Development Fund

  • Created from 5% of increase in VAT collections over preceding year for four years.
  • Funds retained by BIR, automatically appropriated for first year.
  • Use restricted; not for vehicles, salaries, regular positions, or building construction.

Promulgation of Rules and Regulations

  • Secretary of Finance, upon BIR recommendation, must promulgate implementing rules within 90 days of the Act's effectivity.

Repealing Clauses

  • Repeals special laws on franchise tax rates and specific sections in the National Internal Revenue Code.
  • Amendments to Executive Order No. 226 provisions.
  • Partial repeal of VAT application on freight services after two years.
  • Supersedes inconsistent laws, rules, and regulations.

Effectivity

  • The Act takes effect 15 days after complete publication in Official Gazette or newspapers of general circulation, whichever is earlier.

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