VAT Ruling No. 054-91

June 17, 1991 VAT RULING NO. 054-91 Mr. Marcelo M. Lingao MSG Agrivet Enterprise 55 Santiago St.,San Francisco del Monte Quezon City, Metro Manila S i r : About your letter dated November 8, 1990 please be informed that the term, Animal Feeds, under Section 103 (c), NIRC, as amended by Executive Order No. 273, does not include raw materials, ingredients or supplements to animal feeds. It is rather only limited to animal feeds as a complete product. (VAT Ruling No. 021-90, issued January 30, 1990) Your importation of "D-L Methione" which, as per your representation, is used as an essential additive in the formulation and manufacture of animal feeds may not, therefore, be exempted from the 10% Value-Added Tax based on the provisions of the said Section 103 (c). cACHSE Soya bean and fish meals are exempted from the 10% VAT under Section 103 (c) as another independent tax-exempt class in like manner that animal feeds fall under still another separate and distinct tax-exempt class. In short, soya bean and fish meals are VAT-exempt not because the same may be used as materials in the production of animal feeds but simply because Section 103 (c) expressly exempts the same from the 10% VAT as a distinct class. In view of the foregoing, your request that your importation of "D-L Methione" be considered VAT-exempt cannot be granted for lack of legal basis. Very truly yours, (SGD.) JOSE U. ONG Commissioner of Internal Revenue