BIR Ruling

August 18, 1967 The General Manager Sandovals, Incorporated Tangos, Navotas, Rizal S i r : This refers to your letter dated August 1, 1967 requesting that your importations of steel shipbuilding materials for the exclusive use in the construction of your fishing vessels be exempted from the payment of compensating tax pursuant to Republic Act No. 3176 (now Section 190(d) of the Tax Code). In reply, I have the honor to inform you that fishing vessels do not fall within the purview of the amendment effected by Republic Act No. 3176 to Section 190 of the Tax Code. However, under Section 2(e), in relation to Section 6, both of Republic Act No. 3127, as amended, any person, company or corporation engaged or shall engage in deep-sea fishing industry is exempt from the payment of compensating tax in respect of the importation of machinery, spare parts and equipment. Section 8 of the same law prescribes the requirements to be complied with before a certificate of exemption is issued by the Board of Industries to applicants under the provisions of the law. Therefore, unless you present a certificate of exemption duly issued by the Board of Industries, this Office cannot give a categorical during on your request for tax exemption. cdti Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue