BIR Ruling No. 081-65

August 3, 1965 BIR RULING NO. 081-65 Mr. Herminio T. Disini Mercator Finance Corporation P. O. Box 604, Manila S i r : This has reference to your letter dated June 10, 1965 requesting a ruling on the rate of percentage tax on ice-making machines you intend to import. You stated that the primary function of said machine is the production of ice; that it does not have any chamber for cooling beverage or food; that said machine is not for sale but only for lease to hospitals, clinics, hotels and fishing boat operators so they can have a ready source of clean ice cubes or crushed ice for their patients and customers without the inconvenience of buying ice blocks from ice plants and thereafter chopping or crushing them. In your oral representation, you stated that said ice-making machines are primarily intended to meet the insufficiency of the supply of ice which is the main problem of the fishing industry. A machine of said type can be installed in a fishing boat which is capable of supplying the same with enough ice to preserve its catch. This machine can also provide ice to clinics or hospitals in the rural areas where there are no ice plants. In answer thereto, I have the honor to inform you that ice-making machines are subject to 30% sales tax in accordance with Section 185-A of the Tax Code. The ice-machines you intend to import for the purpose of leasing them to others will, therefore, be subject to 30% compensating tax pursuant to Section 190 of the said Code. casia Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue