Title
Tax on sales to/from PEZA enterprises
Law
Bir Memorandum Circular No. 74-99
Decision Date
Oct 15, 1999
BIR Memorandum Circular No. 74-99 establishes the tax treatment for sales of goods, property, and services between suppliers in the Customs Territory and PEZA-registered enterprises, allowing for zero percent VAT on such transactions while outlining specific tax obligations for both parties involved.
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Background and Definitions

  • PEZA-registered enterprises within ECOZONES pay a 5% special tax on gross income, in lieu of all taxes except real property tax.
  • ECOZONES are designated special areas managed by PEZA as separate customs territories.
  • Customs Territory: Philippine national territory excluding ECOZONE boundaries.
  • Sales from ECOZONE to Customs Territory treated as importation by buyer, subject to import duties and VAT.
  • Exported goods and services are VAT-exempt under the "Cross Border Doctrine" which prohibits VAT on goods/services destined for consumption outside the Philippines.

Tax Treatment of Sales from VAT-Registered Suppliers in Customs Territory to PEZA Enterprises

  • Sales of goods to PEZA enterprises under the 5% special tax regime are zero-rated for VAT (indirect export).
  • Sales of services to such PEZA enterprises are also zero-rated for VAT under the cross border doctrine.
  • For PEZA enterprises not under the 5% tax regime (e.g., service establishments), zero rating similarly applies for both goods and services.
  • This zero-rating applies regardless of the PEZA registration class and supersedes prior approval requirements for zero-rating.

Tax Treatment of Sales from VAT-Exempt Suppliers to PEZA Enterprises

  • Sales made by VAT-exempt suppliers to PEZA enterprises are exempt from VAT without regard to the buyer's tax status or the cross border doctrine.

Tax Treatment of Sales Made by PEZA Registered Enterprises

  • Sales of goods by PEZA enterprises to buyers in the Customs Territory are treated as importations by the buyer, who pays import taxes including VAT.
  • PEZA enterprises pay 5% special tax on gross income from such sales, with limitations and possible income tax on excess sales beyond thresholds.
  • For income tax on excess sales, net income is apportioned based on sales ratio.
  • Services sold by PEZA enterprises to Customs Territory buyers are subject to 10% VAT or percentage tax, plus normal income tax.
  • Intra-ECOZONE sales of goods between PEZA enterprises are VAT-exempt.
  • Intra-ECOZONE sales of services by PEZA enterprises under the 5% tax regime are exempt from VAT or percentage tax.
  • Intra-ECOZONE sales of services by PEZA enterprises subject to NIRC taxes are zero-rated for VAT under the cross border doctrine.

Repealing Clause

  • Any inconsistent BIR rulings are amended, modified, or revoked accordingly as of issuance date.

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