BIR Ruling No. 371-2022

REPUBLIC OF THE PHILIPPINES

BUREAU OF INTERNAL REVENUE DEPART'MENT OF FINANCE

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Sec.109(i)(B) of the NIRC BIR Ruling No. 816-2018 of 1997: YATF 3 7 1 - 2 0 22 AUG_2-2 2022

Sacred Heart, Quezon City 1103 SANTEH FEEDS CORPORATION 701 The Richwell Center, #102 Timog Avenue

Attention: Mr. Philip L. Ong President

Gentlemen:

certificate of exemption from value-added tax (VAT) in the manufacture and sale of fish meals, pursuant to Section 109 (1)(B) of the National Internal Revenue Code (Tax Code) of 1997, as amended. This refers to your request on behalf of SANTEH FEEDS CORPORATION for

corporation organized and existing under Philippine laws; that it is duly registered with Incorporation, its primary purpose is "to engage in the business of milling, the Securities and Exchange Commission (SEC); and that as shown in its Articles of supplementary ingredients and/or other cereals, agricultural products, implements and machineries, particularly but not limited to feeds and agricultural chemicals ". manufacturing. processing, packing and repacking, buying and selling at wholesale exporting and importing and otherwise dealing in all kinds of feeds: priniary and Documents submitted show that SANTEH FEEDS CORPORATION, is a

Industry (BAI) with the following Certificates of Registration, to wit: SANTEH FEEDS CORPORATION was issued by the Bureau of Animal

Registration Certificate Feed Establishment BAI Reg. No. Commercial Mixed Feed Manufacturer

Registration Certificate Feed Establishment BAI Reg. No. Feed Importer

Registration Certificate Registration Certificate Feed Establishment Feed Establishment .BAi Reg. No. BAI Reg. No. Commercial Feed Trader Feed Exporter

with License To Operate, to wit:

BAI LTO No. Product Distributor/Importer Veterinary Drug and Valid from July 15, 2020 to July 24,2022

SANTEH FEEDS CORPORATION Page 2 of 7 P YAT- 3 71-2022 AUG 2 2 2022

sale of the following feed products: Records also show that SANTEH FEEDS CORPORATION is engaged in the

2 BREEDER PELLET TATEH CRAB GROWER POWDER TATEH MILKFISH NAME OF PRODUCT CLASSIFICATION Aqua Feed Aqua Feed REGISTRATION NO. BAI FEED PRODUCT 12/31/2021 12/31/2021 VALID UNTIL

6 POWDER PELLET No. 2 PRE-STARTER PELLET STARTER 2 SURFER TATEH EEL FINISHER TATEH RABBITFISH FEED PELLET TATEH CRAB STARTER TATEH MILKFISH PRE- Aqua Feed Aqua Feed Aqua Feed Aqua Feed 12/3 1/2021 12/31/2021 12/3 1/2021 12/31/2021

16 FINISHER ECS PELLET 14 s 10 12 13 9 7PELLET STARTER MASH SURFER PELLET SURFER PELLET PREMIUM CRUMBLE PREMIUM FRY MASH TATEH EEL PRE-STARTER 2 PELLET PELLET SURFER PELLET TATEH CATFISH STARTER TATEH MILKFISH FINISHER PREMIUM TATEH CRAB PRE- TATEH CATFISH FINISHER TATEH CATFISH GROWER TATEH CATFISH STARTER TATEH MILKFISH TATEH EEL GROWER TATEH EEL STARTER TATEH CATFISH STARTER Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed 12/31/2021 12/3 1/2021 12/31/2021 12/31/2021 12/31/202 12/3 1/2021 12/3 1/2021 12/31/2021 12/31/202 12/31/202 12/31/2021 17 EXTRUSINK PELLET

1 20 18 21 22 GROWER ECS PELLET FINISHER SURFER PELLET STARTER SURFER PELLET TATEH MILKFISH GROWER SURFER PELLET TATEH MILKFISH GROWER PREMIUM EXTRUSINK PELLET TATEH MILKFISH TATEH MILKFISH TATEH MILKFISH PRE. Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed 12/3 1/2021 12/31/202 12/31/2021 12/31/2021 12/31/2021

Page 3 of 7 SANTEH FEEDS CORPORATION YAT371-2022 AUG 2 2 2022

23 ].EXTRUSINK PELLET 24 25 26 EXTRUSINK CRUMBLE STARTER SURFER PELLET STARTER PREMIUM EXTRUSINK FRY MASH TATEH MILKFISH TATEH MILKFISH STARTER PREMIUM TATEH MILKFISH STARTER PREMIUM TATEH MILKFISH Aqua Feed Aqua Feed Aqua Feed Aqua Feed 12/31/2021 12/31/2021 12/31/2021 12/31/2021

27 NO.6 FINISHER 1 PELLET TATEH PANGASIUS FEED Aqua Feed 12/31/2021

31 29 30 32 33 28 34 STARTER PELLET N0. 7 FINISHER 2 PELLET TATEH POMPANO NO. 5 MASH TATEH POMPANO NO. 4 GROWER PELLET FINISHER PELLET No. 1 MASH TATEH PANGASIUS FEED TATEH POMPANO NO. 2 TATEH POMPANO NO. 3 TATEH SEABASS FEED TATEH POMPANO NO. CRUMBLE Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed 12/3 1/2021 12/31/2021 12/31/2021 12/31/2021 12/31/2021 12/31/2021 12/31/2021

36 37 35 NO. 2 CRUMBLE NO.4 GROWER 1 PELLET NO. 3 STARTER PELLET TATEH SEABASS FEED TATEH SEABASS FEED TATEH SEABASS FEED Aqua Feed Aqua Feed Aqua Feed 12/31/2021 12/31/2021 12/31/2021

38 NO.5 GROWER 2 PELLET 39 NO. 6 FINISHER 1 PELLET TATEH SEABASS FEED TATEH SEABASS FEED Aqua Feed Aqua Feed 12/31/2021 12/31/2021

43 NO. 7 FINISHER 2 PELLET 40 421 41 NO.4 GROWER 1 PELLET NO.5 GROWER 2 PELLET NO.7 FINISHER PELLET TATEH SNAPPER FEED TATEH SNAPPER FEED TATEH SNAPPER FEED TATEH SEABASS FEED Aqua Feed Aqua Feed Aqua Feed Aqua Feed 12/3 1/2021 12/3 1/2021 12/3 1/2021 12/31/2021

NO. 1 PRE STARTER 1 TATEH SNAPPER FEED Aqua Feed 12/3 1/2021 44 |MASH 451 46 NO. 3 STARTER PELLET CRUMBLE TATEH SNAPPER FEED TATEH SNAPPER FEED NO. 2 PRE-STARTER 2 Aqua Feed Aqua Feed 12/3 1/2021 12/31/2021

47 NO. 6 FINISHER 1 PELLET TATEH SNAPPER FEED Aqua Feed 12/31/2021

48 CL15 PELLET TATEH TILAPIA FINISHER Aqua Feed 12/31/2021

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55 49 50 51 52 53 56 ST 58 54 PELLET PELLET STARTER PELLET PELLET PRE-STARTER EXTRUSINK PELLET EXTRUFLOAT PELLET TATEH TILAPIA PRE- PELLET PRE-STARTER EXTRUSINK TATEH FEEDS TILAPIA FINISHER PREMIUM PREMIUM EXTRUSINK STARTER ZERO SURFER PELLET TATEH TILAPIA STARTER TATEH TILAPIA STARTER PREMIUM EXTRUSINK TATEH VANNAMEI TATEH TILAPIA BREEDER TATEH FEEDS TILAPIA GROWER AMINO PLUS 40 PELLET TATEH MILKFISH TATEH TILAPIA FINISHER CRUMBLE CAGE X CRUMBLE TATEH FEEDS MILKFISH Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed + 12/3 1/2021 12/3 1/2021 12/31/2021 12/31/2021 12/31/2021 12/31/2021 12/31/2021 12/31/2021 12/31/2021 12/3 1/2021

59 EXTRUFLOAT PELLET TATEH MILKFISH STARTER PREMIUM Aqua Feed {2/3 1/2021

61 10 62 63 64 PELLET PELLET PELLET RABBITFISH FINISHER RABBITFISH GROWER PELLET TATEH TILAPIA FINISHER PREMIUM EXTRUFLOAT TATEH TILAPIA GROWER PREMIUM EXTRUFLOAT PELLET TATEH FEEDS RABBITFISH STARTER TATEH FEEDS TATEH FEEDS Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed 12/31/2021 12/3 1/2021 12/31/2021 12/31/2021 12/31/2021

PREMIUM EXTRUFLOAT TATEH TILAPIA STARTER Aqua Feed 12/31/2021

65 "MILKFISH FINISHER CL 15 PELLET Aqua Feed 12/3 1/2021

67 PELLET 66 68 69 TATEH FRY BOOSTER 3 TATEH FRY BOOSTER 2 PELLET MILKFISH GROWER CL 15 Aqua Feed Aqua Feed Aqua Feed 12/3 1/2021 12/31/2021 12/31/2021

Page 5 of 7 SANTEH FEEDS CORPORATION VAY-371 - ZQ2Z AUG 2 2 2022

70 TATEH TILAPIA STARTER SURFER PELLET Aqua Feed 12/31/2021

71 SURFER PELLET TATEH TILAPIA FINISHER Agua Feed 12/31/2021

72 { PELLET 14 3 PREMIUM EXTRUSINK TATEH TILAPIA GROWER TATEH TILAPIA GROWER TATEH TILAPIA PRE- STARTER SURFER PELLET SURFER PELLET Aqua Feed Aqua Feed Aqua Feed 12/3 1/2021 12/31/202 12/31/2021

1S AMINO PLUS 40 PELLET TATEH TILAPIA STARTER PREMIUM EXTRUSINK TATEH TILAPIA STARTER Aqua Feed Aqua Feed 12/3 1/2021 12/31/2021

16 CRUMBLE TATEH TILAPIA STARTER PREMIUM EXTRUSINK Aqua Feed 12/31/2021 77 FRY MASH

781 19 80 81 82 83 FINISHER PELLET GROWER PELLET TATEH VANNAMEI PRE: STARTER 2 PELLET STARTER SURFER PELLET PELLET TATEH VANNAMEI TATEH VANNAMEI STARTER 1 FRY MASH TATEH VANNAMEI PRE- TILAPIA GROWER CL 15 TATEH CATFISH PRE- Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed 12/31/202 12/31/2021 12/31/2021 12/31/2021 12/31/2021 l2/31/2021

TATEH CATFISH PRE STARTER ZERO SURFER Aqua Feed 12/3 1/2021

93 J NO. 5 GROWER 1 PELLET 00 95 NO. 7 FINISHER 1 PELLET 84 85 87 8 94 86 88 91 92 NO. 4 STARTER 2 PELLET POWDER NO. 3 STARTER 1 PELLET PELLET TATEH FRY BOOSTER 1 TATEH GROUPER FEED NO. 2 CRUMBLE TATEH GROUPER FEED TATEH GROUPER FEED NO. 6 GROWER 2 PELLET TATEH EEL FRY POWDER TATEH EEL PRE-STARTER 1 PELLET TATEH FRY SUPPLEMENT TATEH GROUPER FEED TATEH CRAB FATTENER TATEH GROUPER FEED TATEH GROUPER FEED Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed Aqua Feed 12/31/2021 12/31/2021 12/31/2021 12/31/2021 12/31/2021 12/31/2021 12/3/2021 12/31/2021 12/31/2021 12/3 1/2021 12/31/2021

Page 6 of 7 SANTEH FEEDS CORPORATION YAT- 3 7 1 - 2 0 2 z AUG 2 2 2022

96 97 NO.8 FINISHER 2 PELLET TATEH GROUPER NO. 1 FrY MASH TATEH GROUPER FEED Aqua Feed Aqua Feed 12/31/2021 12/31/2021

99 98 TATEH MONODON PELLET STARTER ZERO SURFER FINISHER PELLET TATEH MILKFISH PRE. Aqua Feed Aqua Feed 12/31/2021 12/3 1/2021

100 10 GROWER PELLET TATEN MONODON PRE. STARTER 1 FRYMASH TATEH MONODON Aqua Feed Aqua Feed 12/31/2021 12/31/2021

102 TATEH MONODON PRE. STARTER 2 CRUMBLE Aqua Feed 12/31/2021

104 103 STARTER PELLET TATEH PANGASIUS BROODSTOCK PELLET TATEH MONODON Aqua Feed Aqua Feed 12/31/2021 12/31/2021

105 106 MaSH TATEH PANGASIUS FEED NO. 2 PRE-STARTER 2 CRUMBLE NO. 1 PRE-STARTER 1 TATEH PANGASIUS FEED Aqua Feed Aqua Feed {2/3 {/2021 12/3 1/2021

NO. 3 PRE-STARTER TATEH PANGASIUS FEED Aqua Feed 12/3 1/2021

108 107 NO. 4 GROWER 1 PELLET PELLET TATEH PANGASIUS FEED Aqua Feed 12/3 1/2021

109 NO. 5 GROWER 2 PELLET TATEH PANGASIUS FEED Aqua Feed 12/31/2021

In reply, please be informed that Section 109 (1)(B) of the Tax Code of 1997, as amended by Republic Act No. 10963, provides for the exemption from VAT on the sale or importation of feeds. The aforesaid provision reads, viz:

provisions of subsection (2) hereof, the following transactions shall be exempt from the value-added tax: "SEC. 109. Exempt Transactions. -- (1) Subject to the

fingerlings: fish, prawn, livestock and poultry feeds, including ingredients, whether locally produced or imported, used in the (B) Sale or importation of fertilizers; seeds, seedlings and

manufacture of finished feeds (except specialty feeds for race horses, fighting cocks, aguarium fish, zoo animals and other animals generally considered as pets):

XXX XXX XXX

The words "ingredients" and "feeds" are defined in Section 3 of Republic Act (RA) No. 1556 (An Act to Regulate and Control the Manufacturer, Importation, Labelling, Advertising, and Sale of Livestock and Poultry Feeds), otherwise known as

SANTEH FEEDS CORPORATION Page 7 of 7 VAT- 3 7 1 - 2 0 2 2 AUG 2 2 2022

the "Livestock and Poultry Feeds Act", as amended by Presidential Decree (PD) No. 7 as follows:

"Section 3. Definitions. -- For the purpose of this Act, the following terms shall mean:

XXX XXX XXX

(d) "Feeds" or "Feeding Stuff" shall include all such articles to be used as feeds for the purpose of feeding purporting to supply

proteins, carbohydrates, fats, minerals, vitamins, antibiotics and/or correcting nutritional disorders. Such articles may be locally produced or imported, mixed or in the form of simple ingredients.

XXX XXX XXX

(l) "Ingredients " means any single article of feed or feeding stuff which

enters into the composition of a ration, concentrate, or supplement. "

XXX XXX XXX

Based on the above-cited provision, the distribution/sale of feeds by SANTEH FEEDS CORPORATION is considered exempt from VAT pursuant to Section 109 (1)(B) of the Tax Code of 1997, as amended, provided that the feeds enumerated-above are used exclusively for the production of iivestock and poultry feeds, and not for specialty feeds for race horses, fighting cocks, aquarium fish, zoo animals and other animals generally considered as pets.

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.

Lhal L.Gnds LILIA CATRIS GUILLERMO Commissioner of Internal Revenue H 000806

K-1-JAC