VAT Ruling No. 065-01

October 3, 2001 VAT RULING NO. 065-01 Sec. 109 (d) VAT Ruling Nos. 005-2001, 055-2001 Citadel Enterprises 1013 E. delos Santos Avenue Project 7, Quezon City Attention: Ms. Jinky Pe Tobiano Importer Gentlemen : This refers to your letter dated June 29, 2001 requesting for a ruling that the importation of the following feed ingredients is exempt from the payment of value-added tax (VAT): 1. Feed Oats (BAI Certification No. CIP 01-4864 dated June 6, 2001); and 2. Feed Barley Under Certification Nos. CIP 01-4864 dated June 6, 2001 and CIP 01-2701 dated March 28, 2001, respectively, BAI certified that Citadel Enterprises (Citadel) is registered with their office as feeds/feedstuff importer under registration certificate no. IM-637. In reply, please be advised that under Section 109 (d) of the National Internal Revenue Code (NIRC) of 1997, the sale or importation of fertilizers; seeds, seedlings and fingerlings; fish, prawn, 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) is exempt from VAT. Considering that Citadel is registered with BAI as feeds/feedstuff importer as prescribed under Section 4 of Republic Act 1556, the importation of the above-mentioned articles are exempt from the payment of VAT unless the same qualify as specialty feeds. This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. Very truly yours, Commissioner of Internal Revenue By: (SGD.) EDMUNDO P. GUEVARA Deputy Commissioner Legal and Inspection Group