BIR Ruling

January 7, 1975 Embassy Farms 113 R. Tirona, BF Homes Paraaque, Rizal Gentlemen : This refers to your letter dated January 6, 1975 stating that the Embassy Farms located at Bo. Loma de Gato, Marilao, Bulacan, is a single proprietorship duly registered with the Bureau of Commerce; that firm is engaged in breeding, raising and selling of pigs of various breeds which you sell to retailers, backyard raisers who are borrowers from different Rural Banks and also to commercial hog raisers; that Embassy Farms has its own feed mill; that it buys the raw materials mixed the same and on the whole, the Farm manufacture the hog feeds which are not for sale but exclusively used in feeding of hogs raised in that Farm; and that you also buy various kind of medicines for use exclusively on these pigs. cd Under the foregoing facts, you would like to be informed as to the internal revenue taxes due thereon. In reply, I have the honor to inform you that Embassy Farms for engaging in the business of raising swine for sale is exempt from the payment of internal revenue fixed and percentage taxes prescribed in Section 182(A)(1) and 186, respectively of the Tax Code, pursuant to Section 188(a) of the same Code. Moreover, that farm is not subject to any internal revenue tax for manufacturing hog feeds for exclusive use in feeding the hogs raised in that Farm. However, the income derived by that Farm from the sales of the hogs sold is subject to income tax. cdt Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN 1601-593-5