BIR Ruling

November 16, 1977 The General & Manager Philippine Ports Authority 5th Floor, BF Condominium Bldg. Aduana, Intramuros, Manila S i r : This refers to your letter dated July 15, 1977 requesting information as to what particular provisions of the National Internal Revenue Code and other taxation laws are applicable to that Corporation. In reply, I have the honor to inform you that as stated in our letter to that Corporation dated March 3, 1976, a close study of the pertinent provisions of P.D. No. 857 regarding the activities and objectives of the Philippine Ports Authority, its powers and duties, show that it is a government corporation exercising proprietary functions. As such, it is subject to the P100.00 (formerly P50.00 annual fixed tax prescribed in Section 192(A)(1) [formerly Section 182(A)(1)] of the Tax Code of 1977 and its gross receipts derived from its operation is subject to the 3% contractor's tax prescribed in Section 205 (formerly Section 191) of the same Code. It is also subject to the corporate income tax prescribed in Section 24 of the Tax Code. Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN P4519-F2828-A-8