delivered the opinion of the Court.
' The question is whether a Puerto Rico sales tax imposed by §§ 16 (a), -62 of the Internal Revenue Act of Puerto Rico, (as amended by Act No. 17 of June 3, 1927, Laws of 1927, Special Session, pp. 458-486), is invalid because as applied it infringes Congressional regulations of foreign and domestic commerce effected by the tariff laws and customs regulations of the United States. The tax is challenged so far as it is laid, on the delivery, in consummation of -sales, of fuel oil which has previously been imported in bond and then withdrawn, duty free, for delivery .to Vessels in Puerto Rican ports for use as fuel upon their voyages to ports of the United States or foreign countries. The Court of Appeals for the First Circuit has affirmed the judgment of the Supreme Court of Puerto Rico sustaining the tax, 54 P. R. Dec. 732 (Spanish edition). 108 F. 2d 144. We granted certiorari, 309 U. S. 652, because the question presented is of importance in the administration of the customs, laws of the United States and of the revenue laws of Puerto Rico, and because of an asserted conflict with oür decision in McGoldrick v. Gulf Oil Corp., 309 U. S. 414.
Petitioner brings fuel oil from a foreign country, where it is produced and refined, to Puerto Rico, where it is stored in bonded warehouses in the joint custody of peti*25tioner and the customs officers of the United States, as provided by § 555 of the Tariff Act of 1930, 46 Stat. 743, 19 U. S. C. § 1555, and applicable customs regulations. From time to time petitioner withdraws some of the oil from bond, for disposition and use in Puerto Rico. Petitioner also withdraws some of the oil, with which we are now concerned, and delivers it to vessels in Puerto Rican ports upon sales -for use as ships’ stores in the manner, already indicated. Upon such withdrawal and delivery the import tax imposed on fuel oil by § 601 (a) (c) (4) of the Revenue Act of 1932, 47 Stat. 169, 259-260, and required by § 601 (b) to be “treated for the purposes of all provisions of law relating to the customs revenue as a duty imposed by . . . [the Tariff Act of 1930]” is remitted pursuant to § 309 of the Tariff Act of 1930, 46 Stat.-590, 690 and § 630 of the Act of 1932, added by the amendment of June 16, 1933, 48 Stat. 256.
Section 309 authorizes withdrawal from bonded warehouse, duty free under treasury regulations, of articles of foreign manufacture or production for use as ships’ supplies, and §§ 601 (b), 630 of the Revenue Act of 1932 extend the benefit of those provisions to fuel oil imported in bond and .withdrawn and “sold for use as fuel . . , on vessels . . . engaged in foreign trade or trade . . . between the United States and any of its. possessions.” See McGoldrick v. Gulf Oil Corp., supra, 423 et seq.
It is true, as petitioner urges, that in McGoldrick v. Gulf Oil Corp., supra, we held that the provisions of the Tariff Act of 1930 and of the Revenue Act of 19,32, and the customs regulations relating» bo bonded manufacturing warehouses, when applied to crude oil imported into New York and there manufactured into fuel oil in bonded warehouses and withdrawn duty free for sale as ships’ stores, manifested an intention of Congress ,to regulate the foreign commerce involved, in the interest'of and for the protection of American manufacturers, and that a *26state tax on the sale was invalid because in conflict with such regulation. We do not stop to consider whether, as respondent insists, a different result should be reached here because the imported oil was imported in its manufactured state and was not, as. in the Gulf Oil case, earmarked for manufacture in bonded warehouse and withdrawn after manufacture for sale as ships’ stores. We need not now determine whether standing alone the statutory characterization of the oil sold as ships’ supplies as “exports” within the meaning of the customs laws,. § 309 (b) Tariff Act of 1930; § 630 of the Revenue Act of 1932, does more than make applicable, to it the provisions of the Tariff Act of 1930 for remission of customs duties, upon merchandise imported in bond and later exported. Nor is it necessary to examine the various arguments advanced that the tax, without the consent of Congress, is an infringement of its constitutional power over commerce. For we think a sufficient, answer to all the contentions of petitioner is to be found in the Congressional consent to the tax given by the March 4, 1927 amendment of § 3 of the Organic Act of Puerto Rico, 44 Stat. 1418.
Before the amendment, § 3 had prohibited duties “on exports from Puerto Rico,” but had provided that “taxes and assessments on property, internal revenue” etc., “may be imposed for the purposes of the insular and municipal governments, respectively, as may be provided and defined by the Legislature of Puerto Rico. . . Congress, by the amendment, added to § 3 a proviso “that the internal-revenue taxes levied by the Legislature of Puerto Rico in pursuance of the authority granted by'this Act on articles, goods, wares or merchandise may be levied and collected as such legislature may direct, on the articles subject to said tax, as soon as the same are manufactured,, sold, used, or brought into the island: Provided, That ho" discrimination be made between the articles imported< *27from the United States or foreign countries and similar articles produced or manufactured in Puerto Rico. The officials of the Customs and Postal Services of the United States are hereby directed to assist the appropriate officials of the Puerto Rican government in the collection of these taxes.”
The plain purport of the words of this proviso is that any tax authorized by the Organic Act with respect to articles of domestic production may likewise be levied with respect to imported articles “as soon as . . . [they] . . . are manufactured, sold, used, or brought into the island” provided only that there be no tax discrimination between articles brought from the United States and foreigmcoun-tries and domestic articles. The amendment seems to have been occasioned by doubts which had arisen whether merchandise brought to the Island from the United States' was subject to local taxation while in the original package and also whether the merchandise has, while in the con-, trol of the customs authorities, the same status as respects local taxation as' goods similarly controlled which have been imported from foreign countries and whether 4he power of the insular legislature to tax imports from foreign countries was any greater than that of the states which are . forbidden, by Clause 2, of § 10 of Art. I of the Constitution, to tax imports and exports without the consent of Congress. S. Rept. No. 1011, 69th Cong., 1st Sess., p. 2. Cf. Sonneborn Bros. v. Cureton, 262 U. S. 506, with Baldwin v. Seelig, 294 U. S. 511, 526. These questions were involved in Puerto Rico Tax Appeals, 16 F. 2d 545, decided January 7, 1927, shortly before the amendment of § 3 of the Organic Act. The judgments in that case were reversed and the suits ordered dismissed by this Court for want of jurisdiction, October 24, 1927 (275 U. S. 56), aftef the amendment to the Organic Act of March 4, 1927, which deprived the federal courts of jurisdiction in the pending and other like suits to'restrain the’assessment and collection of Puerto Rico taxes.
*28Moreover practical difficulties appear to have been experienced in levying insular taxes upon goods on their arrival from the United States and while in the custody or control of postal or customs officers, due to the fact that the local tax while in its practical effect a customs duty was not collected by postal or. customs officials. S. Rept. No. 1011, 69th Cong., 1st Sess. The doubts and the.difficulty were removed by the amendment to § 3, giving, the Congressional consent that articles should be subject to the taxing jurisdiction of the Puerto Rico legislature as' soon as brought into the Island whether from the United States or from foreign countries,. and directing that the United States customs officials and postal service should aid .local officers in the collection of the tax. The effect of the broad language of the amendment was not only to subject to taxation all imported goods, whether from the United States or foreign countries, when brought into the Island in the original package, but to neutralize the regulatory effect of.the. customs laws and regulations in so far.as they protected-articles from jlocal .taxation after their arrival.. Merchandise in the original package was thus subjected to tax when brought into the Island without regard to customs regulations. It would, seem plain that other merchandise not in the original package, was left in no more favorable situation and in the face of the broad and unambiguous language of the statute we cannot- say that the one, more than the other, is immune from local taxation. Even if the oil sold as ships’ stores were to be regarded as “exported,”' cf. Swan & Finch Co. v. United States, 190 U. S. 143, 145; United States v. Chavez, 228 U. S. 525; Cunard S. S. Co. v. Mellon, 262 U. S. 100, the tax is one clearly within the terms of 'the proviso added to § 3 and so is one consented to by the United States.
The procedure for segregating imported merchandise in bond, without payment of. customs duties pending its *29-withdrawal and shipment out of the country is old, long antedating the amendment of § 3 of the Organic Act. See McGoldriek v. Gulf Oil Corp., supra. The later Acts of 1930 and 1932 thus placed fuel oil, so far as Puerto Rico is concerned, in the same category as other merchandise brought into the Island in the original package or in bond which, by virtue of the proviso of § 3 of the Organic Act, was made subject to local taxation as soon as brought into the Island. The extension by Congress to fuel oil of the benefits of the customs laws and regulations affecting merchandise imported in bond did not imply that those laws and regulations were to be -given any different effect in Puerto Rico than they then were permitted to have under § 3 of the Organic Act. In any event, considering the relationship of general Congressional legislation to legislation specifically applicable to our territories and possessions, repeals by implication are not to be favored and will not be adjudged unless the legislative intention to repeal is clear. Posadas v. National City Bank, 296 U. S. 497, 501 et seq.
Affirmed.