VAT Ruling No. 004-91

January 29, 1991 VAT RULING NO. 004-91 Romulo, Mabanta, Buenaventura Sayoc & De Los Angeles Fourth Floor, King's Court 2129 Pasong Tamo Street Makati, Metro Manila Attention: Mr . Reynaldo G . Geronimo Gentlemen : This refers to your letter dated October 26, 1989, requesting for, a confirmation that copra cake, the product being traded by your client, Consolidated Coconut Corporation, is exempt from the 10% VAT (VAT Ruling No. 432-88). As presented, copra cake is processed through grinding, drying, expelling of oil and bagging of cake from expeller. The ingredients involved in the process are parings, copra and discarded white coconut meat. In reply, please be informed that the sale of copra cake, also known as copra meal or copra pellets, is subject to VAT under Section 100(a) of the Tax Code, as amended. It may not be exempted from VAT under Section 103(b) of the same Code because it is an agricultural product no longer in its original stake (VAT Ruling 207-88). Neither, may it qualify for exemption from VAT as feeds under Section 103(c) of the NIRC for the reason that more supplements or ingredients to animal feeds are not embraced in the term feeds embodied in this provision (VAT Ruling 021-90 supercedes VAT Ruling 432-88). Very truly yours, JOSE U. ONG Commissioner of Internal Revenue