Tax Exemption on the Exportation by the General Enterprises, Inc. of Logs Abroad as Agent of the Producers

November 13, 1959 BIR RULING NO. 578-59 Mr. Leo Saphiere Export Manager General Enterprises, Inc. 141 Ayala Avenue Makati, Rizal S i r : In answer to your letter dated November 5, 1959, I have the honor to inform you that the exportation by the General Enterprises, Inc. of logs abroad as agent of the producers are exempt from the sales tax, provided that the agency relationship is bona fide . Hence, if the General Enterprises, Inc. in whose name the logs are exported acts as bona fide agent of the producers thereof, no sales tax is due and payable. Accordingly, your foreign buyers may open letters of credit directly to you and you may issue your own commercial sales invoices as brokers for the log producers. However, the General Enterprises, Inc. is, in the exportation of logs of producers for commission, constituted a commercial broker, subject to an annual fixed tax of P150.00 and to the 6% tax on its gross commissions, pursuant to sections 182(s) and 195 of the Tax Code. cdll Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue