BIR Ruling No. 135-84
BIR Ruling No. 135-84 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jul 31, 1984
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July 31, 1984 BIR RULING NO. 135-84 187 (x)-7-81-135-84 Gentlemen : In reply to your letter dated June 26, 1984 requesting a ruling as to whether you should be classified as a manufacturer or contractor, please be informed that for operating and/or maintaining a complete line of equipment, manpower and facilities for toilet soap production for the purpose of manufacturing your own house brand of soap, namely, NOVA . . . and other brand of soap c.f., NEKO soap for your client Warner Lambert Philippines, Inc., wherein you provide the soap base comprising 97.6% of the soap and your client the soap additives comprising 2.4% thereof, you come within the purview of manufacturer as defined under Section 187 (a) of the Tax Code. Accordingly, you are subject to the 10% sales tax on the NEKO soap as prescribed in Section 192(1) and 199(a) respectively of the Tax Code. iatdc Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner
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