BIR Ruling No. 300-82

November 29, 1982 BIR RULING NO. 300-82 202 (d) 025-82 300-82 Mr. Orlando P. Pine, C.P.A. Rm. 507 Ben-Lor Building 1184 Quezon Avenue, Quezon City S i r : This refers to your letter dated September 15, 1982 requesting a ruling on the tax liability of your client, Dupax Timber Equipment Corporation, 3641 P. Sanchez Street, Sta. Mesa, Manila, whose business is purchasing large pieces of lumber at source (square logs longitudinally cut in half, or in four or six pieces); then sawing and transforming these pieces of lumber into marketable shapes and sizes; and afterwards, kiln-drying, chemically-treating and bundling the same for export to foreign buyers. It is represented that the size of lumber you are purchasing from sources are large and not suitable for use in industry; that after sawing and processing by your client, the lumber becomes marketable, durable, seasoned and immediately suitable for applications in the construction of buildings, making of furniture, or other uses that require polish and craftsmanship. In reply, please be informed that, for engaging in the business of buying large pieces of lumber which are not yet suitable for use in industry; then sawing and transforming the same into marketable shapes and sizes; and afterwards, kiln-drying, chemically-treating and bundling the same for export to foreign buyers, your client comes within the purview of a manufacturer under Section 187(x) of the Tax Code subject to the fixed tax of P100.00 per annum under Section 192(l) of the same Code. However, since all of your client's products are exported to foreign buyers, it is also exempt from percentage taxes pursuant to Section 202(d) of the Tax Code, as amended by Batas Pambansa Blg. 84. Very truly yours, RUBEN B. ANCHETA Acting Commissioner