Criteria for Cigarettes Packed by Machine

October 7, 1994 BIR RULING NO. 150-94 Siguion Reyna, Montecillo & Ongsiako 8755 Paseo de Roxas, Philcom Bldg. Makati, Metro Manila Gentlemen : This refers to your letter dated April 15, 1994, stating that your client, Philip Morris Products, Inc., a U.S. corporation, is the owner of a number of trademarks in the Philippines several of which have been used for cigarettes which are manufactured and sold in the Philippines; that your client's licensee in the Philippines, Telengtan Brothers & Sons, Inc., doing business as La Suerte Cigar & Cigarette Factory, has proposed to manufacture and sell in the Philippines Marlboro cigarettes contained in two flip top boxes of ten cigarette sticks per box which are wrapped and sealed together in cellophane and described as "20 Class A Cigarettes." You are requesting confirmation of your opinion that the aforesaid method of packing satisfies the criteria that cigarettes packed by machine shall only be packed in twenties, as provided for in Section 142(c) of the Tax Code, as amended by Republic Act No. 7654. In reply, please be informed that since the two flip top boxes containing ten cigarette sticks per box will be wrapped, sealed and bound together in cellophane, the same may be considered as one whole pack of twenty cigarette sticks. Accordingly, your opinion that the aforedescribed method of packing cigarettes does not deviate from the requirement of said Section 142(c) of the Tax Code, as amended, is hereby confirmed. Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue