January 11, 2008
BIR RULING [ECCP-005-08]
109; R.A. 6938; RR 20-2001; ECCP-002-2003;
ECCP-006-2006; ECCP-043-2007
ISEPI Multi-Purpose Cooperative (IMPC)
Lopez Sugar Corp. Compd., ISEPI Bldg.,
Brgy. Paraiso, Sagay City
Negros Occidental
Attention: Mr. Lucio Ma. B. Barcelona
Chairman of the Board
Gentlemen :
This refers to your letter dated January 5, 2008 requesting for confirmation of your opinion that the sale of sugar produce made by ISEPI Multi-Purpose Cooperative ("IMPC" for brevity) is exempt from the payment of VAT pursuant to Section 109 (L) of Republic Act No. 9337.
The IMPC is an agricultural multi-purpose cooperative duly organized in accordance with Republic Act No. 6938 as evidenced by the issuance of Certificate of Registration No. ILO-3826 dated 11 July 2000. From 2000 up to the present, IMPC remains a cooperative of good standing. Being an agricultural multi-purpose cooperative, among its objectives is to supply production inputs to its members and to market their products. As a consequence, IMPC has been issued by the Sugar Regulatory Administration with the Certificate of Registration as a Sugar Trader.
After its incorporation as a bonafide cooperative, IMPC became a "co-producer" along with...