VAT Ruling No. 015-93

April 26, 1993 VAT RULING NO. 015-93 100 (a) 026-92 015-93 Century Canning Corporation Bo. Bagumbayan, Taguig Metro Manila Attention: Mr . Norman Uy Assistant Comptroller Gentlemen : This has reference to your letter dated October 1, 1992 requesting for a clarification with regards to your sales of canned tuna and sardines to the Philippine National Police Employees Multi-Purpose Cooperative, Inc. As represented, you charge them the 10% value-added tax (VAT) on their purchases but they refuse to pay the VAT claiming that they are exempt from such tax under Article 61 of Republic Act No. 6938. In this connection, you would like to seek for a ruling on whether the cooperative is indeed tax exempt and hence making your sales to them zero-rated. In reply, please be informed that the exemptions granted to cooperatives under Articles 61 and 62 of Republic Act No. 6938 (Cooperative Code of the Philippines) is limited only to taxes to which these cooperatives are directly liable. This being the case, since said tax is an indirect tax, it can be passed on as part of the cost of the goods sold to the cooperative, notwithstanding the tax exemption privileges granted under RA No. 6938. aisadc Very truly yours, VICTOR A. DEOFERIO, JR. Deputy Commissioner (Officer-in-Charge)