BIR Ruling

September 7, 1966 Mr. Teodoro Padilla Padilla Law Office 600-604 Shurdut Bldg. Muralla, Manila S i r : This has reference to your letter dated August 15, 1966 requesting that the invitational premiere showing of the film "The Singing Nun" sponsored by the Catholic Charities, Archdiocese of Manila held at the Ideal Theatre last July 13, 1966, be exempt from the amusement tax. LibLex It appears that the purpose of this project is to generate voluntary contributions for the annual educational and fund drive of the Catholic Charities. The attendance at the premiere showing of said film was wholly upon invitation by His Eminence, the Cardinal-Archbishop of Manila. No tickets or passes were issued, much less sold, at the theatre or elsewhere. All invitations were mailed long before the premiere, to known benefactors of Catholic Charities. In reply thereto, I have the honor to inform you that, under the above representation, it is the opinion of this Office, as it hereby holds that the amounts given by the invited persons to the Catholic Charities were donations pure and simple and not admission fees to the show. Such being the case, the amusement tax prescribed in Section 260 of the Tax Code is not due and payable, said tax being a tax on admission fees to amusement places. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue