BIR Ruling

January 5, 1972 Messrs. Siguion Reyna, Montecillo Belo and Ongsiako A. Soriano Building 8776 Paseo de Roxas Cor. Ayala Ave. Makati, Rizal Gentlemen : This refers to your letter dated October 19, 1971 requesting information as to the business tax status of your client under the circumstances represented as follows: "One of our clients manufacture pouch containers out of specially laminated paper, foil, cellophane and wax paper. Standard processes widely used in the United States and Europe are used by them in the lamination of paper and its subsequent manufacture into containers. As an incidental process in the manufacture of containers, they print certain designs on the laminated stock. The finished containers are subsequently sold to different manufacturers." In reply, I have the honor to inform you that your client, under the above representation, is considered a manufacturer. As such manufacturer it is subject to the fixed tax of P50 per annum prescribed by Section 182(A)(1) of the Tax Code and to the 7% sales tax on its sales of the manufactured products prescribed by Section 186 of the same Code. cdta Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue