Tax Imposed on the Importation of "270 Bulk TINPLATES"

March 24, 1960 BIR RULING NO. 146-60 The Shell Company of the Philippines Limited 1330 Dewey Boulevard, Manila Gentlemen: In answer to your letter of March 10, 1960 wherein you requested this Office to inform the Commissioner of Customs that the "270 Bulk TINPLATES" consigned to you from abroad which, as you stated, you will use in making tin containers of kerosene, are exempt from the compensating tax, please be informed as follows: The exemption from payment of the advance sales and compensating taxes granted by sections 182(B) and 190 of the Tax Code in favor of manufacturers of articles subject to the specific tax covers only the articles imported by them which form part of their finished products. Tinplates are indispensable in making containers of kerosene and these containers are, in turn, necessary in selling kerosene; but, said plates are not, however, part of kerosene which is your finished products subject to specific tax. This Office therefor believes and so holds that your above-mentioned importation is subject to the 7% advance sales tax based on its total landed cost plus 25% mark-up, pursuant to sections 283(B) and 186 of the Tax Code. aisadc Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue