Importation of Fujian or Crude Salt Not Subject to Advance Sales Tax

August 4, 1986 BIR RULING NO. 141-86 162 (c) 118-86 141-86 S i r : This refers to your letter dated July 3, 1986 requesting for and in behalf of your client, Denny's Enterprises, Inc., a ruling to the effect that its importation of Fujian crude salt is subject to 0% advance sales tax. It is represented that in order to augment the present short supply of salt brought about by the heavy rainfall during the months of May and June which melted salt due for harvest during the said period, your client imported Fujian crude salt, a natural agricultural product which does not undergo processing; that they are simply gathered or harvested from the natural salt beds and sold in their original state; and that in order to produce Fujian crude salt, the salt bed is prepared in the same way that agricultural fields are prepared for farming. In reply, please be informed that agricultural food products including ordinary salt whether in their original state or not, are subject to the 0% sales tax, pursuant to Section 165(A)(4) of the Tax Code, as amended by P.D. No. 2006. Accordingly, since the imported Fujian or crude salt in question is an ordinary salt the same is subject to the 0% advance sales tax pursuant to Section 162(c) of the Tax Code as amended by P.D. No. 2031, in relation to Section 165(A)(4) of the Tax Code, as amended by P.D. No. 2006. In other words, your client's importation of Fujian or crude salt is not subject to advance sales tax. Likewise, your client's original sale thereof is not subject to the sales tax under Section 165(A)(4) of the same Code. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner