VAT Ruling No. 050-91

May 29, 1991 VAT RULING NO. 050-91 Worldwide Coco Products, Inc. c/o KING AGRO-MARINE INT'L, INC. Suite 1514 State Centre Bldg. 333 Juan Luna St. Binondo, Manila Attention: Mrs . Benita T . Kiang Accountant S i r s : This refers to your letter dated September 9, 1989 seeking clarification on the following matters, to wit: 1. Are copra meal and copra cake considered as one and the same product?; 2. Is copra cake exempt from value added tax (VAT)?; and 3. If copra cake is VAT-exempt, can input taxes presumably billed be used as tax credit against output tax due on sale of crude coconut oil? In reply, please be informed as follows: 1. Copra meal, otherwise known as copra cake, is a by-product of copra. It comes out in pellet form after the oil is extracted through solvents or pressing. 2. The sale of copra cake is subject to value-added tax pursuant to Section 100(a) of the Tax Code. Such sale cannot be considered exempt under either Section 103(b) or Section 103(c), copra cake being already a processed product ultimately used as ingredient or supplement to animal feeds. 3. All input taxes available to a taxpayer can be credited against his/its output tax due with the exception of those attributable to exempt transactions. LLjur Very truly yours, JOSE U. ONG Commissioner of Internal Revenue