BIR Ruling

November 24, 1976 Kodak Philippines, Ltd. C.C. P. O. Box 620 Makati, Rizal Attention: Mr . Roger L . Em Import Manager Gentlemen : This refers to your letter dated November 16, 1976 requesting confirmation that your importation of shell tube and coil condenser assembly which are integral components of your industrial refrigerating equipment is subject to the 7% compensating tax. It is represented that the imported articles are classified under Central Bank Statistical Classification of Commodities as EP-716-12.05 and EP-716-12.07 (EP-Essential Products);that they are to be used in your photo-finishing laboratories and also for your refrigerated warehouse where you store your stock of unexposed color cinematographic films, unexposed sensitized color papers and other sensitized materials that require refrigeration. In reply, I have the honor to inform you that under the foregoing circumstances and our appreciation of the documents submitted, the aforesaid imported articles are integral components of an industrial refrigerating equipment. Such being the case, they are subject to the 7% compensating tax prescribed in Section 190 in relation to Section 186, both of the Tax Code. Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-1456-040-3 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."