VAT; GTZ Projects - Section 3 of RR No.

6-97 implementing RA 8241 provides that

only those services rendered to persons or entities whose exemption is clearly provided
under international agreements to which the Philippines is a signatory, are effectively
subject to 0% VAT. The Bilateral Agreement between the German Federal Government
and the Government of the Philippines partakes the nature of an international agreement
and is a valid source of tax exemption even without legislative concurrence. Moreover,
the restriction on the use of funds under the Bilateral Agreement is, in effect, a grant of
tax exemption.

Accordingly, GTZ Projects/Project Consultant may not legally be passed on with

the Vat otherwise due from DAP for conducting Training Needs Analysis with the BIR.
(BIR Ruling No. 084-98 dated June 2, 1998)