January 17, 2008
BIR RULING [ECCP-006-08]
109; R.A. 6938; RR 20-2001; ECCP-002-2003;
ECCP-006-2006; ECCP-043-2007
Dos Hermanas Multi-Purpose Cooperative, Inc. (DHMPCI)
Cor. Filipina & Mabini Streets
Talisay City, Negros Occidental
Attention: Mr. Jose Ma. A. Villanueva
Chairman of the Board
Gentlemen :
This refers to your letter dated January 8, 2008 requesting for confirmation of your opinion that the sale of sugar produce made by Dos Hermanas Multi-Purpose Cooperative, Inc. ("DHMPCI" for brevity) is exempt from the payment of VAT pursuant to Section 109 (L) of Republic Act No. 9337. IDATCE
The DHMPCI 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. QC-1295 dated 17 July 1991. From 1991 up to the present, DHMPCI remains a cooperative of good standing. Being an agricultural multi-purpose cooperative, among its services rendered to the members are as follows:
a) provides cash advances to members, particularly for the purpose of procuring chemical fertilizers, organic fertilizers, cane knives and other production inputs;
b) provides tractor services;
c) provides cane hauling services from the farms of its members to the...