Tax Exemption Granted to Silay-Saravia Planters Cooperative Marketing Association, Inc

March 17, 1958 BIR RULING NO. 178-58 Messrs. Garcia, Perlada & Associates Attorneys-at-Law Suite 315, Gonzaga Bldg. Rizal Avenue, Cor. Carriedo Manila Gentlemen : Reference is made to your letter dated March 14, 1958 requesting that your client, the Silay-Saravia Planters Cooperative Marketing Association, Inc., hereafter referred to as the Association, be exempted from the 2% tax prescribed by Section 189 of the Tax Code on the share of its members in the milled sugar which it undertook to be milled by the Central of the Hawaiian-Philippine Company. It appears from the documentary evidence submitted by you that the Association is duly organized under the provisions of Act No. 3425, as amended. It appears also that the Association is undertaking the milling by the Central of the Hawaiian-Philippine Company of the sugar produced by its members and delivered to it as evidenced by the Marketing Agreement and Power of Attorney executed by the planters-members, the Hawaiian-Philippine Company Official Warehouse Receipt and the planter's cane "Weekly Report" and "Daily Report of canes milled". In reply thereto, I have the honor to inform you that, as an association organized under the provisions of Act No. 3425, as amended, your client, in the light of the observations indicated above, is exempt from the 2% tax otherwise due on the share of its members in the sugar which it caused to be milled by the Central of the Hawaiian-Philippine Company. Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue