10% Advance Sales Tax on the Importation of Sausage Casings

February 23, 1987 BIR RULING NO. 060-87 163 (2) 000-00 060-87 Gentlemen : This refers to your letter dated November 20, 1986 requesting that your importation of sausage casings be subject only to 10% advance sales tax. It is represented that Pure Foods Corporation is a domestic corporation principally engaged in the processing and manufacture of fresh meat and canned goods; that among its products are the sausages lines, and that in manufacturing and processing of sausages, imported sausage casings (samples attached) are used. In reply, please be informed that among the essential articles subject to 10% sales tax are processed meat and other processed food products for human consumption. (Section 163(2)(a), Tax Code, as amended by Executive Order No. 36). The imported sausage casings which are raw materials used in the manufacture or preparation of sausages shall be taxed at the same rate as the finished products provided that the importer shall certify to this Office that the imported sausages casings shall be used exclusively in the manufacture or preparations of essential articles subject to tax at 10% (Section 6.II, Revenue Regulations No. 11-86). Accordingly, and in line with your certification dated January 21, 1987 your importation of sausage casings is subject to the advance sales tax at the same rate of 10% based on the total value used by the Bureau of Customs in determining tariff and customs duties, including customs duties and other charges, pursuant to Section 162(c), in relation to Section 163(2), both of the Tax Code, as amended by Executive Order No. 36 which became effective on August 1, 1986. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner