Firm Engaged in Cutting of Paper in Bulk for Sale Not Subject to Manufacturer's Sales Tax and Annual Graduated Fixed Tax

September 24, 1985 BIR RULING NO. 168-85 192 (1) 203-83 168-85 Gentlemen : This refers to your letter dated February 1, 1985 stating that you import glazed coated paper in bulk; that you pay the corresponding advance sales tax due thereon, prior to its release from customs custody, that prior to the sale of the bulk imported glazed coated paper, the same are cut into standard sizes with no chemicals added thereto. Based on the foregoing, you request confirmation of your opinion that your payment of the advance sales tax relieved you from the payment of other tax, annual graduated fixed tax, manufacturer's tax or otherwise. In reply, please be informed that based on the foregoing facts, you are not considered a manufacturer by merely cutting your imported glazed coated paper in bulk into standard sizes which are later sold to your customers. (BIR Ruling No. 203-83) Such being the case, you are not subject to the manufacturer's sales tax nor to the annual graduated fixed tax. You are subject, however, to income tax on any gain derived from such sale. cdta Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner