BIR Ruling No. 038-64

May 18, 1964 BIR RULING NO. 038-64 Messrs. Trajano & Marcelino Certified Public Accountants 433 Regina Bldg., Escolta Manila Gentlemen : Reference is made to your letter dated April 23, 1964 requesting opinion as to whether or not interests paid by importers on trust receipts issued by banks for imported goods form part of the landed cost in the computation of the advance sales. In reply thereto, I have the honor to inform you that the term "landed cost" has been consistently construed as the import invoice value certified to as correct by the Philippine Consul at the port of origin, if there is any, including freight, postage, insurance, commission, customs duty and all similar charges, or all expenses incurred by the importers on trust receipts issued by banks for imported goods form part of the landed cost because they are expenses incurred to import the goods. However, the only interests to be considered as part of the landed cost are those paid or accrued up to the time the imported goods are withdrawn from customs custody. Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue