BIR Ruling

September 7, 1970 Manila Tobacco Association, Inc. 2nd Floor, Suites 4 and 5 505 Arquiza, Cor. A. Mabini St. Manila Attention: B . B . Festin Gentlemen : In reply to your letter dated August 18, 1970, I have the honor to inform you that provincial buying stations of exporters (L-3 dealers) of leaf tobacco are not subject to distinct and separate fixed tax for wholesale dealers (exporters) provided that no sales are made in said buying stations. This Office has consistently held that the mere act of buying does not constitute a taxable business. Accordingly, an exporter of leaf tobacco (L-3 dealer) need pay only a single fixed tax of P1,000.00 prescribed by Section 182(A)(3) of the Tax Codes, as amended by Republic Act No. 6110, even if he maintains branches or stations provided that the latter merely effect purchases without effecting any sale. Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue