BIR Ruling No. 231-83

December 15, 1983 BIR RULING NO. 231-83 Gentlemen : This refers to your letter dated September 17, 1982 addressed to the Ministry of Finance and referred to this Office, requesting that your importation of water chiller be classified under Section 199(a) of the Tax Code. It is represented that your are engaged in the manufacture of PVC pipes for local sales; that as part of your continuing expansion, your purchase from foreign supplier modern machineries to be installed in your newly acquired factory site in the province of Laguna, and; that among the kind and type of machineries/equipment you are planning to purchase is the "water chiller" which is classified as industrial refrigeration equipment. The submitted brochure of the water chiller and the floor plan of the factory show that the manufactured PVC pipes pass to this cooling equipment before they are sawn into desired length. In reply, please be informed that based on your representation and the evidences submitted, your said importation is an integral part of the PVC pipes manufacturing machine; hence, it is subject to the 10% compensating tax prescribed by Section 199(a) in relation to Section 204 of the Tax Code, as amended. The above ruling is based on your representation and the same will be revoked if, after investigation, it is ascertained that the facts are different from those represented. Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue