Taxability of Copra

June 11, 1991 REVENUE MEMORANDUM CIRCULAR NO. 47-91 SUBJECT : Taxability of Copra TO : All Revenue Officials and Employees and Others Concerned For the information and guidance of all officials and employees and others concerned, quoted hereunder in its entirety is VAT Ruling No. 190-90 dated August 17, 1990: "Office of the Commissioner VAT Review Committee (Per RSO 190-89) VAT Ruling No. 190-90 August 17, 1990 COCOFED MARKETING CORPORATION 6th Floor Cocofed Building 144 Amorsolo Street Legaspi Village, Makati Metro Manila Attention: Ms. Esmyrna E. Reyes Vice President-Finance S i r s : This has reference to your letter dated January 16, 1990 wherein you represented that inspite of your VAT registration of your copra trading company, you are supposed to be exempt from VAT on the basis of BIR Ruling dated January 8, 1988 which considered copra as an agricultural food product in its original state. In this connection, you request for a confirmation of your opinion as aforestated. In reply, please be informed that copra, being an agricultural non-food product, is exempt from VAT only if sale is made by the primary producer pursuant to Section 103(a) of the Tax Code, as amended. Thus, as a trading company and a subsequent seller, your sale of copra is already subject to VAT pursuant to Section 9(b)(1) of Revenue Regulations 5-87. This revokes VAT Ruling Nos. 009-88 and 279-88. Very truly yours, (Sgd.) JOSE U. ONG Commissioner of Internal Revenue" As a clarification, this is the present and official stand of this Office unless sooner revoked or amended. All revenue officials and employees are enjoined to give this Circular as wide a publicity as possible. (SGD.) JOSE U. ONG Commissioner of Internal Revenue