Exemption of the Pasudeco Cooperative Marketing Association, Inc.

April 12, 1960 BIR RULING NO. 167-60 Messrs. Garcia, Perlada & Associates Attorneys-at-Law 1589 Mayhaligue St. M a n i l a Gentlemen : In reply to your letter dated April 11, 1960 I have the honor to inform you that the exemption of the Pasudeco Cooperative Marketing Association, Inc. under section 48 of Act No. 3425, as amended by Republic Act No. 702 from the 2% tax on the share of its members in the sugar which it caused to be milled by the Pampanga Sugar Mills, Inc. out of the sugar cane delivered to it by its members for milling extends to its existing and future members. Accordingly, the shares of the Association in the sugar belonging to its new members (planters in the Del Carmen Sugar Mill District) which it caused to be milled by the Pampanga Sugar Mills, Inc., under and by virtue of the "Marketing Agreement and Power of Attorney" executed by the planters in favor of the Association is exempt from the 2% tax. This will serve as authority for the Pampanga Sugar Mills, Inc. from not withholding the 2% on the share of the Association in the sugar which it mills out of the sugar can delivered to it for milling by the Association. Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue