BIR Ruling

January 10, 1975 Mr. Armando A. Orlina Chief Accountant Western Palawan Lumber Corporation Veterans Bank Building Port Area, Manila S i r : This refers to your letter dated December 17, 1974 stating that your company is operating a logging concession in the Province of Palawan; that you are solely engaged in the business of cutting commercial timber and selling the same in the form of sawlogs either to domestic or foreign buyers; that you are not operating any sawmill nor any wood processing plant; that as concessionaire, you are paying the forest charges levied by the Bureau of Forest Development as well as the Bureau of Internal Revenue at Puerto Princesa City, Palawan. Under the foregoing circumstances, you are requesting our opinion as to whether you are liable for the payment of the 7% sales tax on your gross domestic sales of your sawn logs. In reply, I have the honor to inform you that, as producer of logs, the corporation is subject to a fixed tax of P50.00 per annum and to 7% sales on its sales of logs and pursuant to Sections 182(A)(1) and 186 of the Tax Code. However, it is exempt from the sales tax on its export sales. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN 1601-593-5