November 16, 2009
VAT RULING NO. 015-09
Sec. 109 (B) & F; BIR Ruling Nos. 028-00; 127-95; VAT Ruling No. 061-97
Puerto de Oro Milling Corp.
Mambatangan, Manolo Fortich
Bukidnon
Attention: Mr. Alex L. Co
President
Gentlemen :
This refers to your letter dated February 4, 2009 requesting that your services of toll milling poultry feeds is exempt from the imposition of the value added tax pursuant to Section 108 of the 1997 National Internal Revenue Code, as amended.
As represented, your company is engaged in the business of toll milling of poultry feeds; that your business operation involves Agricultural Poultry Integrators like Bounty Foods, San Miguel Foods, Vitarich, etc., providing you with inputs in the form of feed ingredients consisting of agricultural products in their original state like corn, cassava, soya, shells, fish meal, pollard, copra mill, rice bran, salt, molasses, etc.; that these feed ingredients delivered to you by Agricultural Poultry Integrators will be processed in your milling plant by simply grinding and mixing; however, from among the aforementioned ingredients only the corn ingredient is being milled from corn kernel to corn...
