BIR Ruling

November 21, 1973 2nd Indorsement Respectfully returned to the Commissioner of Customs the letter of Mr. Norberto J. Quisumbing dated February 7, 1973 with the information that the importation of underwater hull maintenance equipment described in BXL No. 1 of m.s. Doa Angelina to be used by the importer in the underwater brushing of hulls of ocean-going vessels is subject to the 7% compensating tax based on the total landed cost thereof pursuant to Section 190, in relation to Section 186, both of the Tax Code, as amended. Under paragraph (d) of Section 190 of the Tax Code, as amended by Presidential Decree No. 69 under which the importer claimed exemption, the said imported article will be used merely for brushing or servicing the hulls of the vessels and, therefore, cannot be said to be used by the importer himself as a passenger and/or cargo vessel as envisioned in the law. (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."