BIR Ruling

July 29, 1968 The General Manager Borromeo Corporation 200 2nd St., Por Area Manila S i r : This refers to your letter dated July 26, 1968 requesting that your importations of raw materials to be used in the manufacture of LPG cylinders for export be exempted from the importer's sales tax; and that your export sales of the manufactured LPG cylinders be also exempted from the manufacturer's sales tax. In reply, I have the honor to inform you that under Sections 183(b) and 190(c) of the Tax Code, imported articles to be used by the importer himself in the manufacture or preparation of articles for consignment abroad are exempt from the advance sales or compensating tax. And under Section 188(e) of the same Code, articles shipped or exported abroad by the manufacturer or producer, irrespective of any shipping arrangement that may be agreed upon which may influence or determine the transfer of ownership of the articles so exported are exempt from the sales tax. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue