Exemption Granted to San Carlos Planters' Cooperative Marketing Association

January 6, 1959 BIR RULING NO. 006-59 Messrs. Garcia, Perlada & Associates Attorneys-at-Law Suite 315 Gonzaga Building Rizal Avenue corner Carriedo Manila Gentlemen : Reference is made to your letter dated January 6, 1959 requesting that your client, the San Carlos Planters' Cooperative Marketing Association, Inc., hereafter referred to as the Association, be exempted from the 2% tax prescribed by Section 189 of the Tax Code on the share of its members in the milled sugar, molasses and other by-products, which it undertakes to be milled by the San Carlos Milling Co., Inc., hereafter referred to as the Central. cdta It appears from the documentary evidence submitted by you that the association is duly organized under the provisions of Act No. 3425, as amended. It appears also that the association is undertaking the milling by the Central of the sugar cane produced by its members and delivered to it by virtue of the "Marketing Agreement and Power of Attorney" executed by the members in its favor. In reply thereto, I have the honor to inform you that, as an association duly organized under the provisions of Act No. 3425, your client, for undertaking the milling of the sugar cane produced by its members, is exempt from the 2% tax on the share of its members in the sugar which it caused to be milled by the Central, including molasses and other by-products of sugar cane, pursuant to Section 48 of the said Act, as amended. This will serve as authority for the Central in not withholding the 2% tax on the share of the association in the sugar which it mills out of the sugar cane delivered to it for milling by the association, including the by-products. cdti Very truly yours, (SGD.) MELECIO R. DOMINGO Acting Commissioner of Internal Revenue