BIR Ruling

November 15, 1972 Luzon Brokerage Corporation P. O. Box 591 Manila Attention: Mr . R . M . Millarez Vice President for Customs Affairs Gentlemen : This refers to your letters dated June 22, and July 5, 1972 contending that the 20 pieces of electric cigarette lighters for cars, which your client, Chrysler Philippines Corporation imported, should be subjected to the 7% advance sales tax in view of the provision in Section 184(a) of the Tax Code which reads thus: " Provided, however, That parts and accessories of automobiles imported as replacements or as completely knocked down parts as well as locally manufactured parts and accessories for the assembly of automobiles shall be subject to tax under Section one hundred eighty-six." In reply, I have the honor to inform you that it appearing that the importer is a car assembler, which is subject to sales tax on its manufacture of automobiles, and it appearing further that said lighter are spare parts of automobiles to be assembled by your aforesaid client, the abovementioned twenty (20) pieces of electric cigarette lighters for cars are subject to only 7% advance sales tax, in accordance with the abovequoted provisions of Section 184(a) of the Tax Code. aisadc Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue