BIR Ruling

April 23, 1975 The President Universal Motors Corporation 2232-2234 Pasong Tamo Avenue Makati, Rizal S i r : This refers to your letter dated April 11, 1975 requesting our confirmation that, during your phase-out period, your importations of parts and accessories as completely knocked down parts or as replacements be subject to the 7% advance sales tax and that your manufactured automobiles shall be taxed as "locally manufactured automobiles" under Section 184-A of the Tax Code. In reply, I have the honor to inform you that it appearing in the letter of the Central Bank of the Philippines to that firm dated September 10, 1974 that your request for a phase-out foreign exchange authorization in the amount of $2.19 million for the importation of CKD car packs for 1975, has been approved subject to the conditions therein imposed, your importations of CKD or as replacements to be used in the assembly of your car products during the period of extension are subject to the 7% advance sales tax with a 25% mark-up pursuant to Section 183(b) in relation to Section 184-A(b) and 186, all of the Tax Code. Likewise, your manufactured automobiles shall be taxed as "locally manufactured automobiles" under Section 184-A of the Tax Code. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."