BIR Ruling No. 308-82

March 9, 1982 BIR RULING NO. 308-82 199-a 000-00 308-82 Edward Keller (Philippines) Inc. 2723 Pasong Tamo Makati, Metro Manila Attention: Miss Carmelita C . Briones Assistant Treasurer Gentlemen : This refers to your letters dated February 17 and May 5, 1982 requesting a ruling as to the rate of advance sales tax applicable to your importation of Stepanol AM (Toddler) covered by Invoice No. 3841 and Bill of Lading No. LAXMNL2774 dated January 4, 1982. It is represented that said importation is an ammonium lanryl sulfate which will be used by you as a raw material in the manufacture of Revlon brand "FLEX Shampoo"; that Flex shampoo is used as a cleansing agent for the hair similar to the function of an ordinary toilet soap which is a cleansing agent for the body; and that the cleansing action in Flex shampoo is provided by Stepanol AM derived from coconut oil as a base. aisadc In reply, I have the honor to inform you that the laboratory analysis conducted by this Office show that the aforesaid imported article is a raw material used in the manufacture of shampoo which itself is a saponifiable matter constituting more than 5% in the finished (shampoo) product. Consequently, said importation is considered an ordinary article subject to the 10% advance sales tax based on the landed cost thereof, plus 25% mark-up, pursuant to Section 193(b), in relation to Section 199(a) of the Tax Code of 1977, as amended. Very truly yours, RUBEN B. ANCHETA Acting Commissioner