Tax Imposed on the Publication Received by the American Book Co.

February 24, 1959 BIR RULING NO. 093-59 The American Book Co. 1825 Sandejas, Pasay City Gentlemen : In answer to your letter of the 185th instant, copy of which was submitted to this Office, I have the honor to inform you that publications received by you from your mother company, the American Book Company, United States, and subsequently distributed by you to local schools as samples are subject to the compensating tax of 7%, based on the total landed cost thereof, pursuant to Section 190, in relation to Section 186 of the National Internal Revenue Code. The exemption provided for in the penultimate paragraph of said Section 190 in favor of "any single shipment consigned to any single person when the total value thereof does not exceed one hundred pesos" has application only to non-business importations. Accordingly, and as the purpose in importing and distributing the aforesaid publications is to promote the sales of the books published by your mother company, publications received by you from the United States are subject to the compensating tax irrespective of the value thereof. Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue