BIR Ruling

July 14, 1969 Delta Motors Corp. 2285 Pasong Tamo Makati, Rizal Attention: Mr . Guillermo D . Villanueva Internal Auditor and Tax Consultant Gentlemen : This refers to your letter dated July 8, 1969 requesting information as to the rate of mark-up applicable to your importations of parts and accessories of air conditioners which you manufacture. In reply, I have the honor to inform you that inasmuch as your firm had already been ascertained, after investigation to qualify as manufacturer of "integrated manufactured products" and "non-integrated manufactured products", your importation of parts and accessories for use in your integrated manufactured products like Dash and Trunk motor vehicle air conditioners, Window-type and Split-type room air conditioners, and similar models are subject to 7% advance sales tax based on the landed cost thereof plus 25% mark-up pursuant to Section 183(b) in relation to Section 185(A), both of the Tax Code; and your importation of parts and accessories for use in the manufacture of your non-integrated products, such as Central-type and Multiple units air conditioners are subject to the 15% advance sales tax based on the landed cost thereof plus 50% mark-up pursuant to Section 183(b) in relation to Section 185-A, both of the Tax Code. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue