BIR Ruling

March 7, 1968 Oriana Mfg. & Co. Rm. 209 Genato Bldg. 641 Rizal Avenue Ext. Caloocan City Attention: Mrs . Esther G . Kohtiao Manager Gentlemen : This refers to your letter dated March 5, 1968 stating that you imported materials in bulk and the small empty bottles and jars for which you already paid the corresponding sales tax and other taxes due at the Bureau of Customs; that you are repacking these bulk materials in small containers; and that in the process of repacking, there is no change in the chemical texture of the product being repacked. Under the foregoing facts, you now want to be informed as to whether or not for transfering the imported bulk materials into individual bottles or containers you are considered a manufacturer subject to the sales tax. In reply, I have the honor to inform you that as importer of the Bulk materials who merely transfers the same into individual bottles or containers, you are not considered a manufacturer and, if you have already paid the P20.00 annual fixed tax as importer under Section 182(A)(1) of the Tax Code and the advance sales tax on the imported bulk materials, you are no longer subject to any other business tax. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue