BIR Ruling

July 19, 1976 San Diego Fishery Enterprises, Inc. 462 Carlos Palanca, Sr. St. Quiapo, Manila Attention: Mr . Luis A . San Diego Vice-President Gentlemen : This refers to your letter dated July 12, 1976 requesting that your importation of an industrial integrated ice plant machinery be released from customs custody upon payment of the 7% compensating tax. It is represented that you are engaged in integrated fishing industry; that you imported the aforesaid industrial integrated equipment with a capacity of 50 metric tons per day to be used in the manufacture of your ice requirements for the preservation of the fish that you catch; and that the machine is actually a plant itself. In reply, I have the honor to inform you that under the foregoing description of the nature and use of the industrial integrated ice plant machinery and our appreciation of the brochures submitted, your aforesaid importation is subject to compensating tax at the rate of 7%, to be based on the total landed cost thereof, pursuant to Section 190 of the Tax Code in relation to Section 186 of the same Code. This letter will serve as authority to the Commissioner of Customs to release the abovementioned shipment of industrial integrated ice plant machinery upon payment of 7% compensating tax. Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-1456-040-3