Imported Suede is Subject to 30% Advance Sales Tax While Coated Fabric is Subject to 20% Advance Sales Tax

August 18, 1987 BIR RULING NO. 244-87 163 (4) 264-82 244-87 Gentlemen : This refers to your letter dated August 10, 1987 requesting a ruling as to the rate of advance sales tax payable by you on your importation of "Suede" and "Coated Fabric". You have represented that the aforesaid imported articles are the materials used in the manufacture of shoes; that the same are not made of leather and/or imitation leather nor made of synthetic material. In reply, please be informed that this Office had ruled that the textiles which are under Section 169(g) (now Section 163 (l)(1) of the Tax Code cover only fabrics made by weaving, bonding, felting or tufting. (Ruling No. 264-82 citing Vol. 18, page 170, Encyclopedia Britannica) Thus, it was ruled therein that PVC sheeting and PVC leatherette are not fabrics, hence, not considered textiles. cdta An examination of the samples submitted by you shows that Suede is a fabric since the same is made by weaving; hence, the same is considered a textile. Accordingly, suede is classified as a non-essential article subject to 30% advance sales tax pursuant to Section 163 (l)(1) in relation to Section 162(c) of the Tax Code, as amended. However, the Coated Fabric with cloth backing is not considered textile because the cloth is not made of silk, wool, linen, nylon, or other synthetic or chemical fabric, hence, its importation is subject to 20% advance sales tax pursuant to Section 163 (4) in relation to Section 162 (c) of the same Code. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner