BIR Ruling

October 10, 1973 Messrs. Sycip, Salazar, Luna, Manalo and Feliciano 3rd Floor, Far East Bldg., Buendia Ave., Makati, Rizal Gentlemen : This refers to your letter dated October 5, 1973 requesting confirmation of your opinion that "Guard Hairdressing with ZO-7", a product of your client, Colgate-Palmolive Philippines, Inc., is subject to 7% sales tax. Documentary evidence submitted show that the product is registered with the Food and Drug Administration under CR-1010-73-2. And, in accordance with the registration certificate of the Administration signed by the Administrator himself, no changes in the formulation and commercial presentation of the product shall be made during the effectivity of the registration without the approval of the Administration. The commercial presentation of the product, as approved by the Administration, shows the following: "ONLY MEDICATED GARD CONTAIN ZO-7, AN ACTIVE ANTI-DANDRUFF INGREDIENT PROVEN TO ACTUALLY STOP DANDRUFF." "GARD GROOMS HAIR, STOP DANDRUFF." In reply, I have the honor to inform you that, in the light of the registration of the product with the Food and Drug Administration and of the formulation and commercial presentation thereof as a medicated product, it is the opinion of this Office, as it hereby holds, that "Gard Hairdressing with ZO-7" is subject to only 7% sales tax pursuant to Section 186 of the Tax Code. aisadc Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5