BIR Ruling No. 064-82

March 5, 1982 BIR RULING NO. 064-82 204-00 000-00 064-82 Philippine Coconut Research and Development Foundation, Inc. 5th Floor, Casmer Building Salcedo Street, Legaspi Village Makati, Metro Manila Attention: Mr . Fernando L . Dy Corporate Secretary Gentlemen : This refers to your letter to the Bureau of Customs requesting that your importation of two passenger elevators be exempt from compensating tax. It is represented that you are certified by the National Science Development Board (NSDB) under Republic Act No. 2067, as amended by Republic Act No. 3589, as a private, non-profit, non-stock science foundation organized for the interest of promoting, conducting agricultural and industrial researches and other developmental activities for and within the coconut industry; that you are currently constructing your building at Pasig, Metro Manila to house your headquarters; that part of the building plan is to install two passenger elevators with a 17 person capacity each; and that in order to save money, you intend to purchase both the elevators directly from Japan. cdtech In reply, I have the honor to inform you that the above importation is subject to the 10% compensating tax, pursuant to Section 204, in relation to Section 199 of the Tax Code of 1977, as amended. This Office is of the opinion, and so holds, that your importation does not fall within the purview of Section 24-a of Republic Act No. 2067, as amended, which exempts from taxes, apparatus, instruments, utensils, equipment, and materials imported solely for scientific and technological research and development. Your request for exemption is, therefore, denied. Very truly yours, RUBEN B. ANCHETA Acting Commissioner