BIR Ruling [DA-221-99]

April 13, 1999 BIR RULING [DA-221-99] Bulk Fleet Marine Corporation Rm. 1203 Marbella I 2223 Roxas Blvd., Pasay City Attention: Mr . Salvador C . Ondevilla EVP and Managing Director Gentlemen : This refers to your letters dated October 26, 1998 and February 19, 1999, requesting for a ruling that your importation of crushed, crude and course salt is exempt from the value-added tax. It is represented that your client, in order to augment the short supply of salt brought about by La Nia, imported salt in its crushed, crude and course nature (samples submitted); that the said imported salt are neither iodized nor refined but natural agricultural products produced by gathering salt from natural salt beds and then sun-dried; and that the salt beds are prepared in the same way that agricultural fields are prepared for farming, like the salt-making process used in Cavite and Las Pias. In reply, please be informed that based on your representation, this Office is of the opinion and so holds that the imported crushed, crude and course salt shall be considered ordinary salt in their ordinary state, hence, exempt from the 10% value-added tax pursuant to Section 109(c) of the Tax Code of 1997 (VAT Ruling No. 83-95 citing VAT Ruling No. 16-88). Likewise, your imported table salt which is produced by drying sea water in salt beds and not mined or taken from quarries is not subject to the excise tax imposed under Sec. 151 of the same Code. (BIR Ruling No. 83-95) Very truly yours, Commissioner of Internal Revenue By: (SGD.) SIXTO S. ESQUIVIAS IV Deputy Commissioner Legal and Enforcement Group