BIR Ruling No. 051-64

August 4, 1964 BIR RULING NO. 051-64 Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accountants P. O. Box 589 Manila Gentlemen : Reference is made to your letter dated July 4, 1964, stating as follows: "Our client, Peter Paul Philippine Corporation, is engaged in business as a producer of desiccated coconut. In its manufacturing operations, coconut parings (the outer coverings of the coconut meat) are removed from the coconut meat after the latter has been removed from the coconut shells. The company contemplates to sell these coconut parings "as is", and would like to have your opinion as to whether the sale of such coconut parings "as is" is subject to either the graduated annual fixed tax (C-13) prescribed in Section 182(A)(2) of the Tax Code, or to the percentage tax imposed by Section 189 thereof." In answer thereto, I have the honor to inform you that coconut parings are by-products of coconut and as such, are subject to the 2% tax imposed by Section 189 of the Tax Code. Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue