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PVC Plastic Products Subject to 10% Sales Tax

BIR Ruling No. 204-85 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Nov 13, 1985

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November 13, 1985 BIR RULING NO. 204-85 199 (a) 264-82 204-85 Gentlemen : This refers to your letter dated September 24, 1985 requesting that your manufactured non-woven PVC plastic sheeting be subject to the 10% sales tax under the Code, as amended. You have represented that like any PVC sheeting manufactured locally, it involves different raw materials such as PVC resins, plasticizers, fillers, pigments, lubricants and stabilizer which are mixed in the banbury machine; that it goes through the calendar machine where the thickness of the PVC sheeting is adjusted; that the sheeting then passes to the embossing and printing machine for the making of different designs that a piece of grey cloth or non-woven materials is then laminated as a lining and to make it stronger and easier to handle by the users; and that this is then called the PVC leatherette. (sample attached) In reply, please be informed that textile which are taxed under Section 196(g) of the Tax Code covers only fabrics made by weaving, knitting, bonding, felting, or tufting. (Vol. 18, page 170, Encyclopedia Britanica). The PVC sheeting in question is not fabric; hence, it is not considered a textile. With respect to the PVC leatherette, which is the PVC sheeting with cloth backing, the same is not also considered textile because the cloth is not silk, wool, linen or nylon but cotton. The cloth backing is not the chief value of the product. In view thereof, this Office believes and so holds, that the PVC plastic products in question are subject to the 10% sales tax imposed by Section 199(a) of the Tax Code, as amended. aisadc Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner

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