BIR Ruling

June 19, 1972 Reinsurance Brokers Philippines, Inc. Makati, Rizal Attention: Mr . Antonio M . Umlas Gentlemen : This refers to your letter dated May 22, 1972, requesting information on the kind of tax that corporation will be subject to for engaging in business as outlined in the primary purpose of its Article of Incorporation, which is as follows: "To carry on business as reinsurance brokers or advisers, as consultants or as representative (as general agents, or as managers, or as special agents, or in any other representative or agency capacity as may now or hereafter be allowed by law or applicable government regulations) of any domestic and/or foreign life or non-life insurance company or companies authorized to do business in the Philippines or insurance clients, as the case may be, and, in pursuance thereof, to solicit, place and procure all kinds of life and/or non-life insurance business (the latter including but not limited to fire, marine, workmen's compensation, personal accident, firearms, fidelity and surety bonds, and placements of reinsurance of such risks, that it may engage for the purpose) and generally, to do and perform those various acts and things which are necessary, proper and/or incidental to the purpose herein defined." cdta In reply, I have the honor to inform you that under the foregoing primary purpose, that corporation is an independent contractor subject to the annual fixed tax of P50.00 and to the 3% tax on its gross receipts in accordance with Sections 182(A)(1) and 191 of the Tax Code, as amended by Republic Act No. 6110 (BIR Ruling No. 72-003 dated February 22, 1972) Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue