BIR Ruling

November 3, 1970 The President Consolidated Motor Corporation P.O. Box 1524 Manila S i r : This refers to your letter dated October 29, 1970 requesting confirmation that the gas stove you propose to manufacture locally is subject to the 7% sales tax and your importation of parts to be used in the manufacture of said gas is also subject to the 7% advance sales tax. It is stated in your letter that in the manufacture of gas stove, you manufacture within the manufacturing enterprise more than 80% of the total quantity of the intermediate components and parts of the finished product, such as: (1) Stainless Steel Top, (2) Side Panel, (3) Front Panel, (4) Back Panel, (5) Burner Support, (6) Link for Case, (7) Switch Panel, (8) A Panel, (9) Damper A, (10) Damper B, (11) Air Adjuster A, (12) Air Adjuster B (13) Air Adjuster C, (14) Air Adjuster D, (15) Ignition Seat, (16) Band for Plug, (17) Reflection Tray, and (18) Packaging Carton Box; and that the parts imported by you to be used in your local manufacture of gas stove are the following (1) Burner, (2) Ignition Assembly, (3) Trivet, (4) Knob, (5) Inlet Pipe, (6) Pilot Nozzle and (7) Grill Assembly. In reply, I have the honor to inform you that under the foregoing circumstances, your locally manufactured gas stove is subject only to the 7% sales tax pursuant to Section 185(i) in relation to Section 186, both of the Tax Code, as amended by Republic Act No. 6110. Moreover, your importation of parts to be used in your manufacture of the aforementioned gas stove is subject to the 7% advance sales tax, said tax to be based on the landed cost thereof plus 25% mark-up pursuant to Section 183(b) in relation to Section 186, both of the Tax Code. aisadc This ruling is subject to revocation should it be found after investigation that the facts are different from those represented. Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue