BIR Ruling No. 052-64

August 7, 1964 BIR RULING NO. 052-64 Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accountants P. O. Box 589, Manila Attention : Mr . V . O . Jose Partner Gentlemen : This is with reference to your letter dated July 31, 1963 requesting confirmation of your opinion based on the following facts: cdtech "One of our clients, a corporation engaged in manufacturing, was granted tax exemption under Republic Act 901. During the period of its tax exemption transfers of manufactured products from its tax-exempt department t its taxable department were treated as bona fide sales subject to the graduated rates of tax exemption as provided under Republic Act 901. "At the expiration of the tax exemption privilege granted the above company, we believe that transfers from one department to another department can no longer be treated as a sale for tax purposes inasmuch as inter-department transfers within the same company cannot be considered as sales . . .." In answer thereto, I have the honor to inform you that this Office is of the opinion and so holds that at the expiration of the exemption privileges granted to new and necessary industry, transfers of manufactured product from its tax-exempt department to its taxable department should not be treated as sale for tax purposes. aisadc Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue