Applicability of BIR Ruling No. 110, series of 1959

April 19, 1960 BIR RULING NO. 176-60 The President Republic Electronics and Film Incorporated Lopez Building, Aduana M a n i l a Gentlemen : Reference is made to your letter requesting information as to the applicability of BIR Ruling No. 110, series of 1959, to your operations. You stated that the Republic Electronics & Films, Inc., hereafter referred to as Republic, was created solely for the purpose of servicing exclusively the Bolinao Electronics Corporation and the Chronicle Broadcasting Network. These services consist of film procurement and maintenance of studio and transmitter equipment. You adopted this et-up instead of establishing a separate maintenance film procurement department in each network because you find it more efficient and economical. You state further that Republic is managed by the same officers managing the two TV networks. In other words, you are representing that the three corporations are sister corporations and Republic is purely an adjunct to the two. BIR Ruling No. 110, series of 1959 is to the effect that imported TV films are exempt from tax under the provisions of Republic Act No. 1919 only when imported by TV companies for exclusive use in TV broadcasts. If your query refers to the taxability of the importations by Republic of TV films for the use of its two sister corporations, this Office is of the opinion and so holds that, inasmuch as such importations are actually for the exclusive use of the two TV companies effected by Republic for and their behalves, the imported TV films are exempt from tax pursuant to Republic Act. No 1919. cdll Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue