BIR Ruling [DA-059-96]

February 2, 1996 BIR RULING [DA-059-96] K-9 Trainors & Breeders, Inc. Governor Drive, Mabuhay, Carmona Cavite Attention: Mr . Michael Alunan Gentlemen : This refers to your letter dated November 14, 1995, requesting exemption from the value-added tax of your importation of dog food. It is alleged that the dog food which you imported from Holland are not for sale but exclusively for your dogs; and that your stock of dogs are not pets but working dogs being trained by you for the use of the Philippine National Police and the Armed Forces of the Philippines in bomb and explosive detection, narcotics sniffing, sentry and perimeter guarding, control and VIP protection and assault. In reply, I regret to inform you that, notwithstanding the foregoing reasons, this Office cannot grant your aforesaid request and instead reiterates the previous VAT Ruling No. 211-90 which revoked VAT Ruling Nos. 016-88 and 051-88, to the effect that the importation of dog food is subject to the 10% value-added tax imposed under Section 101 (a) of the Tax Code, as amended by E.O. No. 273, and as implemented by Section 7 (a) of Revenue Regulations No. 5-87. Very truly yours, ALICIA P. CLEMENO Assistant Commissioner (Legal Service) By: ALICIA L. TOMACRUZ Head Revenue Executive Assistant (Legal Service)