BIR Ruling

July 26, 1966 Joaquin Cunanan & Co. Certified Public Accountants San Martin Bldg. 1564 A. Mabini, Manila S i r : This refers to your letter dated June 17, 1966 stated in the following manner: LibLex "We respectfully request your confirmation that seaweeds should be classified as agricultural products. Seaweeds grow naturally on the seashore and are abundant when there is a reef. They could also be cultivated or grown artificially depending on the particular location. What is known as "gulaman" is one of the examples of seaweeds. They are edible like vegetables except that they are grown in seawater." In reply, I have the honor to inform you that the term agricultural products is not limited to vegetable substances directly resulting from the tillage of the soil, but includes everything which serves to satisfy human needs which is grown upon the land, whether it pertains to the vegetable kingdom, or the animal kingdom. (Molina vs. Rafferty, 38 Phil. 547). Based on the foregoing definition, seaweeds may be considered agricultural product if actually cultivated. If taken from the sea they cannot be considered as agricultural product for then they are not grown upon the land nor the direct result from the tillage of the soil. LLpr Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue