BIR Ruling No. 115-61

March 22, 1961 BIR RULING NO. 115-61 Mico Record Mfg. Co. P. O. Box 2364 Manila Attention : Mr . Eusebio Contreras Manager Gentlemen : This is with reference to your letter dated January 11, 1961, requesting information as to whether the imported raw materials used in the manufacture of phonograph records of all speeds are subject to the advance sales tax at the rate of 30%, or 7% only. cdta It appears that your company is a manufacturer of phonograph records; that it has been paying, likewise, an advance sales tax of 30% on its imported raw materials used in the manufacture of said records; and that the raw materials used in the manufacture of phonograph records of all speeds are as follows: Vinylite Resin VYHH 3 Kodalith Film Monohydroas Tribasio Surfacer Recording Lacquer Lead Sulphate Mirosil Silver Solution Calcium Stearate Label Printing Paper Waxes Golden Rod Masking Paper Vincol Resin Offset Plates Blown Asphalt Blank Recording Tapes Carbon Black Chemical Reagents Record Compound Based on the foregoing facts as presented, I have the honor to inform you that the abovementioned imported raw materials, being the component parts of the finished products (phonograph records), are subject to the advance sales tax at the same rate of 30% as the manufactured products, pursuant to Section 185(g), in relation to the last paragraph of the same section, Tax Code, as amended. cdti However, the marked-up value of said imported raw materials actually used in the manufacture of phonograph records may be deducted from the gross selling price or gross value in money of such manufactured records, pursuant to the first paragraph of the same section of the Code abovestated. Accordingly, your company, as manufacturer of phonograph records, committed no error in its payment of the percentage taxes due the Government. cdt Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue