BIR Ruling No. 055-62

February 19, 1962 BIR RULING NO. 055-62 The Caltex (Phil.), Inc. P. O. Box No. 783 M a n i l a Gentlemen : Reference is made to your letter dated November 9, 1961, requesting opinion whether or not your importations of spare parts and accessories for use as replacements of worn-out parts and accessories of coastwise tankers or marine crafts which you use in transporting petroleum products to the different parts of the Philippines are subject to the compensating tax provided for in Section 190 of the Tax Code, as amended by Republic Act No. 3176. In reply thereto, I have the honor to inform you that, pursuant to the Explanatory Note of House Bill No. 5801 which became Republic Act No. 3176, the purpose of exempting from the compensating tax passenger and cargo vessels, as well as engines and spare parts thereof, is to help the shipping business. Such being the case, and considering that the company is engaged in the business of petroleum products and not in the business of shipping, this Office is of the opinion and so holds that the importations in question are not covered by the exempting provisions of said amendatory Act and, therefore, subject to the compensating tax. liblex Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue