25% Compensating Tax — Tamifelt

August 24, 1981 BIR RULING NO. 162-81 204 091-79 162-81 Universal Robina Corporation E. Rodriguez Avenue Pasig, Metro Manila Attention: Miss Jeanette Uy Yu Asst . to the President Gentlemen : This refers to your letter dated June 23, 1981 requesting reconsideration of our ruling contained to the Authority To Release Imported Goods No. NARD- 2-0006950 dated June 2, 1981 wherein your importation of 2 bales Tamifelt was subjected to 25% compensating tax under Section 196 (g) in relation to Section 204, both to the Tax Code of 1977, as amended. You stated that since said shipment consists of ordinary articles to be used exclusively as filtering felt for your feed milling machinery to filter dust in order to control pollution, the same should be subject only to 10% compensating tax under Section 204 in relation to Section 109, both of the Tax Code of 1977, as amended. In reply, please be informed that according to the findings of this Office, felt "Is a resilient unwoven fabric commonly of textile materials (wool, fur, cotton, nylon and other natural or synthetic fibers) compacted by pressure and/or heat". (BIR Ruling No. 18-80 dated September 18, 1980). Under Section 196(g) of the Tax Code, as amended, textiles wholly or is chief value of silk, wool, nylon or other synthetic and/or chemical fabrics except those primarily intended for clothing are subject to 25% percentage tax. Accordingly, and since the Tamifelt imported by you will be used in your feed milling machinery, the same are subject to the 25% compensating tax, pursuant to Sections 196(g) and 204 of the Tax Code of 1977, as amended. If the imported article will be sold, bartered or exchanged by you, the same will be subject to the advance sales tax. cdtech Very truly yours, RUBEN B. ANCHETA Acting Commissioner