BIR Ruling [DA-514-99]

September 3, 1999 BIR RULING [DA-514-99] Samar Coco Products Manufacturing Corp. Rm. 1510 State Centre Building #333 Juan Luna St., Binondo, Manila Attention: Mr . Raymond Co S i r : This refers to your letter dated June 25, 1999 requesting for a certification to the effect that your by-product, copra meal/copra cake is exempt from VAT. In reply, I regret to inform you that your request cannot be granted for lack of legal basis. In VAT Ruling No. 207-88 dated May 27, 1988, this office held that ". . . based on the information given by the Philippine Coconut Authority, copra cake meal which may come in pellet form is the by-product of copra after the oil is extracted through solvents or pressing. Said by-product is used in the manufacture of animal and poultry feeds. ". . . copra cake can no longer be considered as being in its original form. And, since only agricultural and marine food products in their original form are exempt from VAT pursuant to Section 103(b) of the NIRC, as amended by EO 273, copra cake, is therefore, subject to VAT." cdlex Very truly yours, (SGD.) SIXTO S. ESQUIVIAS IV Deputy Commissioner (Legal & Enforcement Group)