BIR Ruling

October 6, 1975 Mr. Artemio N. Capuno Rm. 410 Chaco Building Plaza Cervantes, Binondo Manila S i r : This refers to your letter dated September 1, 1975 requesting information as to whether the consular fee which is paid to Philippine Consulates abroad in securing the consular invoice or merchandise is included in the taxable value of an imported article for purposes of determining the landed cost of an imported article. In reply, I have the honor to inform you that the term "landed cost" has been consistently construed to mean the invoice value plus freight, postage, insurance, commission, customs duty and all similar charges, or all expenses incurred by the importer before the release of the goods from customs custody. Since the consular fee is a necessary expense incurred by the importer to complete his importation, such expense falls within the purview of the term "all similar charges" as contemplated in Section 183(b) of the Tax Code and, therefore, the same forms part of the landed cost for purposes of computing the advance sales tax due on the imported article. cdta Very truly yours, (SGD.) EFREN I. PLANA Actg . Commissioner of Internal Revenue TAN-1456-040-3