Tax Liability of a Fisherman Who Salts His Catch for Sale

February 9, 1960 BIR RULING NO. 047-60 Mr. Alonzo P. Espaola 1306 Pennsylvania Street M a n i l a S i r : In answer to your letter dated January 9, 1960, I have the honor to inform you the following: A fisherman who salts his catch for sale is a manufacturer. As such manufacturer, he is subject to a fixed tax of P20.00 per annum and to 7% sales tax on his sales of the salted fish. The sales tax is paid monthly and is based on gross selling price less cost of tax-paid raw materials in accordance with the provisions of section 186 of the Tax Code. The cost of boxes purchased from the manufacturers thereof and used as containers is deductible, but the cost of salt is not. The cost of salt, boxes, gasoline, diesel fuel and kerosene can be allowed as deductible operating expenses in the computation of net income for income tax purposes. LLphil Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue