BIR Ruling No. 083-64

December 28, 1964 BIR RULING NO. 083-64 Business System Division P. O. Box 1909, Manila Attention : Mr . Thomas B . Cort General Manager Gentlemen : This has reference to your letter dated October 28, 1964, addressed to the Hon. Secretary of Finance which was referred to this Office on October 30, 1964, requesting a ruling on the question of whether or not imported "Thermo-Fax" copying paper is subject to 30% advance sales tax. LLjur Under BIR Ruling No. 62-0124, dated November 15, 1962, this Office has ruled that "Thermo-Fax" copying machine is subject to 30% advance sales tax prescribed by Section 183(b) in relation to Section 185(j) both of the Tax Code. The imported "Thermo-Fax" copying paper appears to be specially and exclusively prepared for the use of the "Thermo-Fax machine. It is so chemically coated or impregnated that the beat of infrated rays produced by the machine effects the desired reproduction of the original on the copying paper. Its designs and chemical composition are so properly fitted with that of the machine that the latter will be useless or cannot be used or any other purpose except with the "Thermo-Fax" copying paper. Such being the case, the "Thermo-Fax" copying paper is considered an accessory of the machine. Since the said copying paper is an accessory of the "Thermo-Fax" copying machine, it is necessarily subject to 30% advance sales tax pursuant to the last paragraph of Section 185 of the National Internal Revenue Code reading "Any part or accessory of the abovementioned articles shall be taxed at the same rate as the finished articles". Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue