VAT Ruling No. 021-90

January 30, 1990 VAT RULING NO. 021-90 100-000-00-021-90 Atlas Fertilizer Corporation Ground Floor, Tuscan Building Herrera Street, Legaspi Village Makati, Metro Manila Attention: Atty . Vicente P . Romano, Jr . Corporate Counsel Gentlemen : This refers to your letter dated February 7, 1989 requesting confirmation of your opinion that Di-calcium and Tri-calcium Phosphate are exempt from the value-added tax in accordance with Sec. 103(c) of the Tax Code as amended. It is represented that you are engaged in the manufacture of Di-Calcium from limestone and phosphoric acid and Tri-calcium Phosphate from rock phosphate and phosphoric acid; and that per information from the BIR Laboratory both products, while they are finished products, serve as dietary and nutrient supplements for animal feeds. In reply, please be informed that based on the foregoing facts, this office does not confirm your opinion that Di-calcium and Tri-calcium phosphates are indeed finished animal feeds that can qualify for exemption from VAT. Accordingly, their sale being ingredients of animal feeds is subject to VAT pursuant to Section 100 of the same Code. aisadc Very truly yours, JOSE U. ONG Commissioner of Internal Revenue