A copy of the Board of Investments (BOI) registration cannot take the place of the BOI

Certification required under RMO 9-000 to effect the

automatic VAT zero-rating of sales to a BOI firm.
The certification should state that the company is a
BOI-registered manufacturer/producer whose
products are 100% exported.
RMO simply aims to relieve said BOI firms from the
tedious requirement for application of effective zerorating.
It does not, in any way, preempt their right to
claim refunds or tax credit for their unutilized input
taxes on purchases not covered by RMO 9-2000.
(BIR VAT Review Committee Ruling No. 018-2005,
September 13, 2005)\

Revenue Memorandum Order No. 9-2000

Issued March 29, 2000 prescribes the conditions for the automatic zero-rating of sales of goods,
properties and services made by VAT-registered suppliers to BOI-registered manufacturers-exporters
with 100% export sales, to wit: 1) the supplier must be VAT-registered; 2) the BOI-registered buyer must
likewise be VAT-registered; 3) the buyer must be a BOI-registered manufacturer/producer whose
products are 100% exported as certified by the BOI; 4) the BOI-registered buyer shall furnish each of its
suppliers with a copy of the BOI Certification; and 5) the VAT-registered supplier shall issue for each sale
to BOI-registered manufacturer/exporters a duly-registered VAT invoice with the words "zero-rated"
stamped thereon.

PURSUANT to Revenue Memorandum Order (RMO) 9-2000, the sale of goods, properties or
services made by a value-added tax (VAT)-registered supplier to a company registered with the
Board of Investment (BOI) and whose products are 100-percent exported shall be accorded
automatic VAT zero-rating.

The BOI-registered buyer shall furnish each of its suppliers a copy of the certification issued by
the BOI, which shall serve as authority for the supplier to avail of the benefits of zero-rating for
its sale to the said BOI-registered client.

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If a local supplier passes on VAT to the BOI-registered firm certified as a 100-percent exporter,
the registered firm can apply such input VAT for refund or for the issuance of tax credit
certificate (TCC) since such input VAT is attributed to export sales, which are subject to zero-
percent VAT.

In principle, however, no output tax should be shifted by local suppliers to the BOI-registered
firm if it has been issued a BOI certification. Hence, to be entitled to the refund, the BOI-
registered firm should show clear and convincing proof that its local supplier actually passed on
or shifted the VAT on its domestic purchases. Without such proof, the claim for refund shall be
denied. (Philex Mining Corp. versus Commissioner of Internal Revenue, CTA Case No. 7115,
March 10, 2009)