BIR Ruling No. 025-82

February 3, 1982 BIR RULING NO. 025-82 192-1 014-62 025-82 Atty. Toribio L. Peralta 1744 Sampaguita Street Dasmarias Village Makati, Metro Manila S i r : This refers to your letter dated January 4, 1982 requesting information as to whether or not your client, Mr. Herman Vitas, 2471 Leon Guinto Street, Malate, Manila, is subject to the graduated annual fixed tax (C-13). You have represented that your client is a manufacturer-exporter of shell necklace, bracelets, pendants, earrings and other allied products made out mainly of sea shells; that the raw materials used are being purchased from licensed gatherer who are residents of the areas near the seashore in many different places in the islands of Luzon, Visayas and Mindanao; that they gather, collect and clean the raw shells after which they deliver them to your client; that your client in turn, cuts, arranges, assembles, tumbles, strings and puts or glues the shells together to form the finished products; and that these finished products are being exported abroad to different countries and no sales are made locally. In reply, please be informed that under the foregoing facts, your client is a manufacturer-exporter exempt from the sales tax, but subject to the annual fixed tax of P100.00 prescribed in Section 192(1) of the Tax Code, as amended. His sales are not also subject to the graduated annual fixed tax. Moreover, your client is subject to income tax. cdtech Very truly yours, RUBEN B. ANCHETA Acting Commissioner