Taxability of the Shipment of Listerine Essence, Boric Acid Essential Oil and Aluminum Carbohydrate

October 10, 1958 BIR RULING NO. 554-58 Muller & Phipps Manufacturing Corporation P. O. Box 950, Manila Gentlemen : With reference to your letter dated October 6, 1958 requesting the exemption from tax of your shipment of listerine essence, boric acid essential oil and aluminum carbohydrate which will be used in your manufacture of Listerine Antiseptic and Odorono Spray Deodorant, I have the honor to inform you that said shipment is subject to 7% advance sales tax. LLpr While it is true that articles to be used by the importer himself in the manufacture of articles subject to the specific tax and are to form part thereof are not subject to the advance sales or compensating tax, nevertheless, the Listerine Antiseptic and Odorono Spray Deodorant manufactured by you are not actually subject to the specific tax. What was subjected to the specific tax is the alcohol content thereof which was paid by the distiller. The principle of law stated in our letter of May 16, 1958 is correct but its application cannot extend to your case. prll Very truly yours, (SGD.) MELECIO R. DOMINGO Acting Commissioner of Internal Revenue