BIR Ruling No. 321-2020

REPUBLIC OF THE PHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Sec.1091Aof the Tax

BIR Ruling No.221-17 Code of 1997:

VATG321-2020 JUN 1 5

Pangasinan 2444 Sitio Sili, Brgy. Ungib, San Quintin, QUICKGROW GENETICS PHILS., INC.

Attention :Mr. Aristotle O. Santos President

Gentlemen:

of the 1997 Tax Code, as amended. importation and distribution of corn seeds and livestock, pursuant to Section 109 (1)(A) QUICKGROW GENETICS PHILS., INC. for value-added tax (VAT) exemption on its This refers to your letter dated January 18, 2017, requesting on behalf of

its Articles of Incorporation, its primary purpose is to be able to produce superior pig the world and making it available to local pig farmers to help uplift the hog industry. and existing under Philippine laws; that it is duly registered with the Securities and genetics with the introduction of imported lines from reputable pig sources from around Exchange Commission (SEC) under SEC Reg. No. Taxpayer's Identification Number (TIN) Documents submitted show that QUICKGROW GENETICS PHILS., INC., with is a corporation organized ; and that as shown in

importer of plant product(s) such as Corn seeds with Certificate of Registration No. animals, semen and other genetic materials with Certificate of Accreditation No. period of two (2) years. Records also show that QUICKGROW GENETICS PHILS., INC. is a registered issued on October 24, 2017, by the Bureau of Animal Industry, valid for a issued by the Bureau of Plant Industry; is an accredited importer of live

amended by Republic Act No. 9337, provides for the exemption from VAT on the sale or importation of corn seeds and livestock. The aforesaid provision reads, viz.: In reply, please be informed that Section 109 (1)(A) of the Tax Code of 1997, as

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

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Page 2 of 2 Quickgrow Genetics Phils., Inc. VAT-0321-2020 JUN 1 5 2023

products in their original state, livestock and poultry of a kind generally used as, or yielding or producing foods for human consumption; and breeding stock and genetic materials therefor." A) Sale or importation of agricultural and marine food

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seeds in their original state and livestock used as, or yielding or producing foods for human consumption, is considered exempt from VAT pursuant to Section 109 (1)(A) of the Tax Code of 1997, as amended. It is not subject to twelve percent (12%) VAT imposed under Sections 106 (A) and 107 (A) of the 1997 Tax Code, as amended. It is understood that the necessary government permit/accreditation/authority for the importation/distribution/sale of said corn seeds and livestock have been properly secured. Based on the above-cited provision, the importation and distribution/sale of corn

However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. This ruling is being issued on the basis of the foregoing facts as represented.

Very truly yours,

wecMy

Commissioner of Internal Revenue CAESAR R. DULAY

K-1-JAC 034282