BIR Ruling

August 10, 1973 F. M. Benitez & Associates Certified Public Accountants 667 United Nations Avenue Manila Gentlemen : In reply to your letter dated May 17, 1973, I have the honor to inform you that the previous ruling of this Office holding that hospitals fall within the purview of the term "independent contractors" under Section 191 of the Tax Code, as amended by Presidential Decree No. 69 and, therefore, subject to the contractor's fixed and percentage taxes under Sections 182 (A) (1) and 191, respectively, both of the Tax Code, was revoked and superseded by the ruling of this Office dated June 20, 1973. Such being the case, hospitals, whether charitable/religious or not, are not subject to the said taxes. cdtech Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue TAN 1601-593-5 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR"