BIR Ruling

April 1, 1970 2nd Indorsement Respectfully returned to the Director, GSIS General Hospital, East Avenue, Quezon City the within letter of Atty. Gerardo Cabo Chan, Legal Counsel of Philippine Bed Factory, dated March 11, 1970 together with attachments relative to the question of whether or not Philippine Bed Factory is subject to the 3% contractor's tax in connection with latter's contract with the GSIS on the supply, delivery and installation of foam rubber mattresses for the GSIS Hospital. acd A perusal of the papers shows that the contract entered into by and between the GSIS and the Philippine Bed Factory is a contract of sale of foam rubber mattresses. Such being the case, the Philippine Bed Factory is not subject to the 3% contractor's tax imposed by section 191 of the Tax Code, as amended by Republic Act No. 6110. MISAEL P. VERA Commissioner of Internal Revenue