VAT Ruling No. 049-92

April 1, 1992 VAT RULING NO. 049-92 NIRC Sec. 103 (b) Precedent Ruling 122-90 Ms. Concepcion C. Limon Rm. 409 Victoria Bldg. 11th Ave., Caloocan City M a d a m : This refers to your letter dated September 10, 1991 requesting for a ruling whether the following taxpayers are exempt from the 10% Value-Added Tax: 1. Wholesale traders of salt who purchase salt in bulk from producers; and 2. Wholesale traders of fish. In reply, please be informed that pursuant to Section 103(b) of the National Internal Revenue Code (NIRC), as amended, agricultural and marine food products, e.g., salt and fish, are exempt from the 10% value-added tax in all stages of production and distribution if sold in its original state. Marine salt produced from sea water and industrial salt produced from salt mines are considered still in their original state if they have not yet undergone recrystallization process; while fish is considered in its original state even if it has undergone the simple processes of preparation or preservation for the market, such as freezing, drying, salting or smoking. Based on the foregoing, your queries are answered as follows: 1. Wholesale traders of salt (purchased in bulk from producers) which are still in its original state shall be exempt from VAT pursuant to Section 103(b) of the Tax Code, (VAT Ruling No. 122-90) 2. Wholesale traders of fish (whether fresh, frozen; salted, dried or smoked) are likewise exempt from VAT pursuant to Section 103(b) of the Tax Code. TCcIaA Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue