BIR Ruling No. 027-82

February 5, 1982 BIR RULING NO. 027-82 199-00 000-79 027-82 Mayon International Brokerage Corporation 2nd Floor T.P.A. Bldg., 7496 Bagtican St. Pasong Tamo, Makati Attention: Mr . Miguel R . Diputado Executive Vice-President and General Manager Gentlemen : This refers to your letter dated April 9, 1981 requesting reconsideration of our ruling contained in the Authority to Release Imported Goods No. IT-80-0004419 dated March 24, 1980 wherein the importation of washing and sterilizing equipment by your client, Wyeth-Suaco Laboratories, Inc. was subjected to 25% compensating tax imposed by Section 204 in relation to Section 196, both of the Tax Code of 1977, as amended. It is represented that the aforesaid shipment which is covered by Bill of Lading No. 09657 will be used exclusively by Wyeth-Suaco Laboratories, Inc. for washing and sterilizing milk pipes which are part of the processing machine for milk; that said equipment will be used in the manufacturing plant as a replacement unit to form part of the processing system; and that said shipment is actually a composite equipment and an integral part of the milk manufacturing operation. In reply, please be informed that it being represented that the aforesaid shipment will be used exclusively by your client as a replacement unit, and considering that said article is a composite equipment forming an integral part of the milk manufacturing machinery, the same is subject only to 10% compensating tax, pursuant to Section 204 in relation to Section 199, both of the Tax Code of 1977, as amended. However, if said imported article will be sold, bartered or exchanged, the same shall be subject to the advance sales tax. cdtech Very truly yours, RUBEN B. ANCHETA Acting Commissioner