Importation of Marine Solar Salt Exempt from 10% Value-Added Tax

February 5, 1998 BIR RULING NO. 009-98 103 (c)-000-00-009-98 Salinas (IM) Corporation 33 Scout Rallos Street, Quezon City 1103 Metro Manila Attention: Mr . Paul Dela Cruz Vice President for Operation Gentlemen : This refers to your letter dated September 22, 1997 which was referred to this Office by the Department of Finance, in effect, requesting a ruling that your importation of marine solar salt is exempt from VAT. Based on the Certifications submitted by Cargill Australia Ltd., "marine solar salt may be classified as ordinary salt since its production is thru the process of solar evaporation of ordinary sea water (brine) over large areas of enclosed ponds and earthen dikes and does not undergo further processing except washing with high concentrated brine." LLphil In reply, please be informed that pursuant to Section 103 (c) of the Tax Code, as amended by R.A. No. 7716 and as further amended by R.A. 8241, the sale or importation of agricultural and marine food products in their original state is exempt from the value-added tax. Ordinary salt is considered agricultural product in its original state. Accordingly, your importation of 4,783 metric tons of marine solar salt which arrived in the Port of Limay, Bataan on May 27, 1997, is exempt from the 10% value-added tax imposed under Section 101 (a) of the Tax Code, as amended. This ruling is subject to revocation if it turns out later that the certifications which you submitted are not genuine. Very truly yours, (SGD.) LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue