Tax Exemption of Exporter of the Logs Produced by Him

June 11, 1958 BIR RULING NO. 315-58 Gonzalo Puyat & Sons, Inc. 190 Rodriguez Arias, San Miguel Manila Gentlemen : This is in connection with your letter dated January 7, 1958 requesting opinion on the following: "A" had an order for logs from a foreign firm. To fill this order, "A" entered into an agreement with "B", a local producer to supply the logs on the basis of FOB exporting vessel, Philippine port, the export license having been applied by "A" and in "A's" name. The negotiation of the shipping documents have been made by "A" as the holder of the letter of credit. From the above recited facts, A is the exporter of the logs and not B. Section 188(e) of the Tax Code exempts from the percentage tax only articles shipped of exported abroad by the manufacturer or producer thereof. Inasmuch as B is not the exporter of the logs produced by him, he cannot be exempted from the percentage tax imposed in Section 186 of the National Internal Revenue Code. Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue