VAT Ruling No. 048-98

December 2, 1998 VAT RULING NO. 048-98 107 (a)-000-00-048-98 Vitarich 5th Floor, Sarmiento Bldg. II 2316 Pasong Tamo Extension Makati City Attention: Mr . Rene R . Eleria Division Head Materials Management Division Gentlemen : This refers to your letter dated September 11, 1997 requesting for a ruling to the effect that your importation of Tapioca Chips/Pellets is exempt from the value-added tax. Based on your representation and brochures submitted, Tapioca Pellets come from Tapioca Chips while Tapioca Chips come from Tapioca Roots; and that the said products which are imported from Thailand are feed ingredients which can also be used for pig and poultry diets. In reply, please be informed that Section 103(d) of the Tax Code, as amended by R.A. No. 7716, as further amended by R.A. No. 8241 (now Sec. 109(d) of the Tax Code of 1997), exempts from VAT the sale or importation of livestock and poultry feeds, including ingredients , whether locally produced or imported, used in the manufacture of finished feeds (except specialty feeds for race horses, fighting cocks, aquarium fish, zoo animals and other animals generally considered as pets). Such being the case, and considering that as per your shipping documents and other related documents submitted to us, tapioca chips/pellets are "feed ingredients", your importation of 5,500 MT of Tapioca Pellets FAQ is exempt from the 10% value-added tax imposed under Section 107(a) of the Tax Code of 1997, and provided finally that said tapioca chips/pellets are not ingredients of specialty feeds as above-stated. LLpr This ruling is being issued based on the facts as represented. However, if upon investigation it shall be disclosed that the facts are different then this ruling shall be considered null and void. Very truly yours, (SGD.) BEETHOVEN L. RUALO Commissioner of Internal Revenue