BIR Ruling No. 070-64

November 19, 1964 BIR RULING NO. 070-64 The Shell Chemical Company (Philippines) Inc. P. O. Box 441 Manila Gentlemen : Reference is made to your letters dated April 17 and May 28, 1964 requesting the rate of tax due on your manufacture of Shelltox with Vapona used for killing domestic pests. In answer thereto, I have the honor to inform you that while the Shelltox with Vapona is said to contain a solvent, mineral turpentine, established to be a petroleum product and constitutes the chief ingredient of the product, nevertheless the same is purely a raw material and not the product being manufactured. Accordingly, for manufacturing Shelltox with Vapona, you are subject to the fixed annual tax of twenty (P20.00) pesos and to the 7% sales tax on the sales of the said product pursuant to Sections 182(A)-(1) and 186, both of the National Internal Revenue Code. However, in your first mentioned letter of April 17, 1964, you stated that your company had commenced sale of this product to the public as early as February 1963 or more than one (1) year from the date of said letter. Accordingly, this ruling is issued without prejudice to whatever action may be properly taken in the light of the circumstances, in the event that the taxes due on the product so sold have not been paid. cdtech Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue