BIR Ruling No. 103-63

December 27, 1963 BIR RULING NO. 103-63 The R. G. Wales & Company R-304 Trade & Commerce Bldg. 215 Juan Luna St.,Manila Gentlemen : This has further reference to our letter to you dated June 13, 1963 relative to the rate of advance sales tax collectible on the so-called "Eichner Drycopy" machine. In our said letter, this Office authorized the payment of only 7% advance sales tax on your importation of said machines subject to the condition that if upon investigation, the machine should be found to be a contact copying machine, deficiency advance sales tax be collected thereon. In the demonstration conducted before two (2) attorneys of the Law Division of this Office, it was shown that the machine effects a reproduction by simply placing the instrument desired to be copied on top of a pliable paper to which was inserted the so-called Eichner drycopy paper and the set rolled thru, the machine. The machine, therefore, represents a typical example of a contact copying machine contemplated by Section 185(j) of the Tax Code. In view of the foregoing, the machines in question are subject to 30% advance sales tax pursuant to Section 185(j) of the Tax Code. You are, therefore, requested to pay the deficiency advance sales tax on the importation in question. cdt Very truly yours, (SGD.) RAMON T. OBEN Acting Commissioner of Internal Revenue