Commercial Pilot's Privilege Tax Exemption for Unpaid Services Rendered During Training

January 14, 1958 BIR RULING NO. 027-58 Messrs. Lobrin, Vecino & Associates Lawyers and Tax Consultants Suites 314-315, Yuchengco Bldg. 484 Rosario, Manila Gentlemen : Reference is made to your letter dated December 20, 1957, requesting information as to whether or not, based on the following facts, your client, the Philippine Refining Co., Inc. is subject to any tax: "My client, the Philippine Refining Company, Inc. imported hessian bags for use as containers for its products which it exports abroad. In the course of exportation, that is, while the filled bags are being loaded on the outgoing steamer, some got destroyed and the contents have to be placed in some other bags. The destroyed bags are brought back to the bodega, and now there are about 4,000 of them. To clear the bodega of these destroyed bags, it is contemplated either to burn them or to sell them for whatever use they may be to the buyers." In answer thereto, I have the honor to inform you that if the aforementioned bags will be actually burned, no tax need be paid thereon by your said client. On the other hand, if the bags are sold to others, there will be due thereon a sales tax of 7%, based on the actual selling price thereof. Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue