Toll Manufacturing (CMT) vs Finished Goods Sales
A garment workshop works in two ways: toll sewing, where the customer supplies fabric and trims, and full production, where the workshop supplies the materials. Toll sewing is a taxable service. The tax base of a service is the consideration (VAT Law Article 1(17) read with Article 1(19)), meaning the sewing fee, and Article 23 withholding of 2% follows PMK 141/PMK.03/2015. Finished clothes made with the workshop’s own materials are taxable goods. Their tax base is the selling price (Article 1(17) read with Article 1(18)): the money charged for the goods, excluding VAT and a discount stated on the Tax Invoice. For supplies other than luxury goods, VAT is a 12% rate times an other-value base of 11/12 (PMK 131/2024 Article 3). Neracia separates draft invoices for goods and toll services so the tax base stays accurate.