Graduated Annual Fixed Tax — Dealer-Exporter

October 5, 1981 BIR RULING NO. 194-81 192-2 000-00 194-81 Atty. Bienvenido E. Somera 21 Wisdom St., Carmel Subdivision Quezon City S i r : This refers to your letters dated September 9 and 14, 1981 requesting information in behalf of your client, E. V. Nera Enterprises as to what tax it is liable on the exportation of black stones. It is represented that your client has entered into a contract with a Japanese firm for the exportation of Philippine Black Stones to Japan; that said stones are gathered along the shoreline of Luna, La Union by residents of the said municipality without digging or excavating; that said stone gatherers are given permit by the Bureau of Mines upon payment of a license fee prescribed by the said Bureau, and also pay their license and permit to the municipal government in accordance with the local ordinance; that your client buys the stones by cans from the said gatherers over whom it has no control; that your client in turn directly export these stones to Japan; and that the only business activity of your client is the exportation of black stones to Japan. In reply, I have the honor to inform you that under the foregoing facts, your client is considered a dealer-exporter subject to the graduated annual fixed tax prescribed in Section 192(2) of the Tax Code of 1977, as amended, the initial amount of which is P20.00. Thereafter, the amount of tax will depend upon the amount of gross sales during the preceding calendar year. Moreover, your client is subject to income tax. Very truly yours, TOMAS C. TOLEDO Deputy Commissioner