BIR Ruling No. 066-82

March 5, 1982 BIR RULING NO. 066-82 187-x 000-75 066-82 Pacific Oil Products, Inc. 707 Trade and Commerce Bldg. Juan Luna Street, Manila Attention: Mr . Alberto C . Go General Manager Gentlemen : This refers to your letter dated August 11, 1980 requesting confirmation of your opinion that refined coconut oil is subject to the 2% miller's tax prescribed by Section 205 of the National Internal Revenue Code, based on the actual gross selling price or market value thereof. You contend that coconut oil refining is basically the purification of crude coconut oil, broken down into the following basic steps: 1. Caustic refining 2. Hot water washing 3. Bleaching 4. Deodorizing that while the refining process involves a series of steps, all these steps lead to only one thing purification of the oil; and that the input (crude coconut oil) comes out as the end product basically unchanged. In reply, I have the honor to inform you that the term "coconut oil" mentioned in Section 203 of the Tax Code does not include refined oil or cooking oil, which before it becomes marketable as such, undergoes the above separate and more complicated process with the crude coconut oil as the basic raw material. In other words, crude coconut oil undergoes manufacturing because by chemical process, its quality is altered thereby reducing it to marketable shape. [Sec. 187(x), Tax Code]. In view thereof, this Office believes, and so holds, that refined oil or cooking oil is subject to the 10% sales tax prescribed by Section 199(a) of the Tax Code. Very truly yours, RUBEN B. ANCHETA Acting Commissioner