BIR Ruling

June 17, 1969 The Manager Philippine Rolling Steel Corporation 1241-1245 Gen. Luna St. Ermita, Manila S i r : This refers to your letter dated June 9, 1969, requesting information as to what business tax you are liable to for engaging in the following business activities: "(a) We are fabricating roll-up doors according to various sizes fitted to the gauge of galvanized iron used in their construction; "(b) We keep regular stocks of raw materials used in the manufacture of these doors; "(c) We have ready-made stocks of our manufactured products. Sometimes, different customers, such as construction dealers, home owners for the construction of these doors give certain specifications to suit their establishments; "(d) There are actually three (3) standard sizes of these doors which we are manufacturing and these are based according to the gauge of G.I. used and the dimensions of the door; "(e) In some instances, the customers avail of our technical know-how in the installation of manufactured doors for which we are paid a separate fee." In reply, I have the honor to inform you that under the foregoing facts you are a manufacturer and a contractor. For manufacturing roll-up doors, you are subject to the annual fixed tax of P20.00 and to the 7% sales tax on your sales of manufactured roll-up doors, pursuant to Sections 182(A)(1) and 186 of the Tax Code. For undertaking the installation of your manufactured doors to some customers for a separate fee, you are considered a contractor, subject to the annual fixed tax of P20.00 and to the 3% tax, in accordance with Sections 182(A)(1) and 191 of the Tax Code. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue