BIR Ruling

January 19, 1970 The President Pacific Star Inc. 1033-1035 R. Hidalgo St. Manila S i r : This refers to your letter dated January 15, 1970 requesting information as to the rate of sales tax due on imported ammonia compressors of the type shown in the brochure submitted which are represented to be installed in an ice plant. In reply, I have the honor to inform you that it being represented that the amounts compressors will be installed in an ice plant of your customer the same are subject to the 7% advance sales tax based on the landed cost thereof plus 25% mark-up pursuant to Section 183(b) in relation to Section 186, both of the Tax Code. However, if said compressors will be used for refrigeration of air conditioning systems the same are subject to the 40% sales tax imposed in Section 185-A of the Tax Code, as amended by Republic Act No. 6110. Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue