BIR Ruling No. 265-61

June 29, 1961 BIR RULING NO. 265-61 Timoteo Y. Rodelas Trading Room 208 Garcia Building 636 Rizal Avenue, Manila Gentlemen : Reference is made to your letter of the 27th instant, requesting information whether or not the business of importing lumber, in which you are about to engage, is already covered by your C-13 and C-14 privilege tax receipts. In a conversation with you on the matter, we have been made to understand that you are at present engaged in the business of exporting logs bought from concessionaires and timber operators and that of importing papers, for which you are provided with the C-13 and C-14 privilege tax receipts, respectively. It is stated in your said letter that the lumber to be exported are sawn from logs you purchase from concessionaires and that you have them sawn by established sawmills. In answer thereto, I have the honor to inform you that, under the circumstances, in addition to your businesses as exporter of locally purchased logs and importer of papers, you are a manufacturer or producer of lumber. Such being the case, and considering that the business of manufacturing or producing lumber is separate and distinct from the two businesses mentioned, it follows that the privilege tax receipts you are now holding do not cover said business, for which another privilege tax should be paid under Section 182(A)(1) of the Tax Code. In this connection, it may be stated that your sales of exported lumber are exempt from the 7% sales tax imposed in Section 186 of said Code, pursuant to Section 188(e) thereof. cdll Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue