Court Resolution Dated 10 January 2018 (Administrative Adjustments on Legal Fees)

November 9, 1960 BIR RULING NO. 539-60 A. D. Santos, Inc. City Cab Laurel St., Mandaluyong Rizal Gentlemen : In reply to your letter dated November 8, 1960, I have the honor to inform you that your importation of completely knocked down parts of Mercedes Benz diesel cars for use in your taxicab service, said cars to be assembled by the authorized assembly plant of Mercedes Benz, shall be subject to either the 50%, 75% or 100% compensating tax as the case may be, under section 184 of the Tax Code based on the total landed cost of the cars. The privilege of the reduced rate of tax on automobiles imported in completely knocked down parts and accessories can be availed of only when the importer thereof is an automobile manufacturer or car assembler who makes such importation for the purpose of assembling them into finished automobiles. aisadc Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue