10% Advance Sales — Imported Garlic

April 27, 1981 BIR RULING NO. 078-81 198-0 000-00 078-81 Commissioner Romulo M. Espaldon Commission for Islamic Affairs Philcomcen Bldg., Ortigas Ave. Pasig, Metro Manila S i r : This refers to your letter dated March 15, 1981 bearing on the request of four (4) MNLF Returnees headed by Datu Disumimba H. Rashid for tax exemption on the 10,000 metric tons of garlic which they plan to import from Taiwan. In reply, I regret to inform you that the above request cannot be granted for lack of legal basis. Imported garlic being an agricultural product, is subject to the 10% advance sales tax based on the landed cost thereof, plus 25% mark-up, in accordance with Section 198, in relation to Section 193(b), both of the Tax Code of 1977, as amended. aisadc Very truly yours, RUBEN B. ANCHETA Acting Commissioner