BIR Ruling

January 23, 1974 Atty. Romeo L. Luna 8th Floor, Bank of P.I. Bldg. Ayala Avenue, Makati, Rizal S i r : This refers to your letter of even date requesting authority to release from Customs custody upon payment of the 7% compensating tax your client's (Sikatuna Fishing Corporation's) importation of "7 packages of Refrigeration Equipment and Parts, B/L No. Y M-7 'Austral', Voyage 5". It is represented that subject importation are merely parts and accessories of importer's fish for export ice and cold storage facilities in Zamboanga City which use ammonia as refrigerant. In reply, I have the honor to inform you that your client's instant importation of parts and accessories of industrial refrigeration equipment is subject to the 7% compensating tax pursuant to Section 190, in relation to Section 186, both of the Tax Code, as amended. cdt Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."