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CIR vs. Seagate Technology (Philippines)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, versus SEAGATE TECHNOLOGY (PHILIPPINES), Respondent.

G.R. No. 153866 | 2005-02-11



THIRD DIVISION
DECISION

PANGANIBAN, J.:

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...