10% VAT on Imported Raw Materials to be Used in the Manufacture of Fish, Animal and Poultry Feeds

March 18, 1988 BIR RULING NO. 113-88 101 (a) 000-00 113-88 Gentlemen : This refers to your letter dated January 21, 1988 requesting confirmation of your opinion that your importation of raw materials/ingredients to be used in the manufacture of fish, animal and poultry feeds are exempt from the value-added tax, viz: cdta Activated Powder Tri-Nitro Ascorbic Acid Biotin 2% Calcium DL Vitamins Ethoxyqium Powder Pantothenate Ethylene Diamine Fish Meal Flic Acid Dihydriodide Methionine Alimet Monoprop Plus Niacin/Nicotinamine/ Potassium Phosphate Gentian Nicotinic Dibasic Riken Fish Liver Zinc Hacitracin Thiamine Ho Vitamin DL Methionine Meat & Bone Meal Choline Chloride L-Lysine Soykomilk Methoionine Corophyl Yellow Lutavit Vitamins Hydroxy Analogue & Red Sodium Ascorbate Soy Bean Meal Lactic Acid Selenium Premix Tapioca Flour Yellow Corn Santoquin Mix #6 Santoquin Liquid Tricalcium Phos- Ethoxyqium Liquid Inositol phate Lucantin CX Pellan E/Exdaon FLD Text Fead Wheat Burley Text: FS Inosticol Feed Grade Manganese Sulfate Riboflavin In reply, please be informed that the foregoing imported raw materials to be used in the manufacture of fish, animal and poultry feeds are subject to the value-added tax of 10% based on the total value used by the Bureau of Customs in determining tariff and customs duties plus customs duties, excise taxes, if any, and other charges, such tax to be paid by the importers prior to the release of such goods from customs custody pursuant to Section 101(a) of the Tax Code as amended by Executive Order No. 273. Under Section 103(c) of the same Code, only the importation of fish, animal and poultry feeds is exempt from the value-added tax . In other words, the exemption covers only the manufactures feeds and not the raw materials used in the manufacture of said feeds as in the instant case. cdti Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner