BIR Ruling

September 5, 1972 Mr. Macario I. Silva 1210 Peafrancia, Paco Manila S i r : In reply to your letter dated February 3, 1972, I have the honor to inform you that this Office cannot give a definite answer to queries (a) and (d) posed in your letter unless this Office is furnished with detailed information as to the actual business activities of the persons and entities therein mentioned. However, with respect to question (e), please be informed that a person who is engaged in the sale of supplies and fuels for motor vehicles, such as motor oil, grease, gasoline, etc., is liable for the payment of the graduated annual fixed tax prescribed in Section 182(A)(2) of the Tax Code, as amended. For servicing, repairing and tuning up motor vehicles, he is a contractor subject to the contractor's fixed and percentage taxes prescribed in Sections 182(A)(1) and 191, respectively, of the Tax Code. Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue