BIR Ruling No. 139-82

April 22, 1982 BIR RULING NO. 139-82 193-b 000-78 139-82 Philippine Poultry Industry Association 10-G New York, Cubao Quezon City Gentlemen : This refers to your letter dated June 2, 1980 requesting in behalf of Lipa City Multi-Purpose Cooperative Association (LIMCOMA) exemption from the payment of advance sales tax on the importation of meat and bone meal which arrived on May via SS Neptune Crystal covered by Bill of Lading No. LB/MA-003. Documentary evidence submitted show that LIMCOMA Marketing Cooperative, Inc. is a duly registered cooperative with Certificate of Registration No. R-IV-FF-047RR dated December 1, 1978 having complied with the requirements of the Ministry of Local Government and Community Development; that it was organized primarily to engage in the purchase or procurement and sale of all kinds of farm in-puts, such as supplies, materials, tools, and equipment needed in farming, orchard growing, poultry and livestock raising, including fertilizer, seeds, seedlings, poultry and animal feeds; veterinary drugs and farm chemicals; to engage in the purchase, processing and sale of all kinds of products from farms, orchards poultry and livestock farms especially of its members; to represent and act for and on behalf of any/or all its members in securing adequate allocations for them from any and all institutions, private or governmental, of any or all farm in-puts, such as subsidized fertilizers, seeds, seedlings and other supplies and materials, tools and equipment that may be needed in connection with farming, orchard growing, poultry and livestock raising, and to distribute the same to its members in accordance with the rules and regulations prescribed for such distributions. In reply, I have the honor to inform you that although the said cooperative is registered with the Ministry of Local Government and Community Development pursuant to Section 8(b) of Presidential Decree No. 175, and therefore, exempt from income and sales under Section 5(a) of the said Decree, the above importation of the cooperative is however, subject to the payment of the 5% internal revenue tax, pursuant to Section 1 of Presidential Decree No. 1352, as amended by Presidential Decree No. 1395. cdtech Very truly yours, RUBEN B. ANCHETA Acting Commissioner