BIR Ruling

February 14, 1969 Mr. Felipe Monserrat c/o The Philippine Athletic Association of the Philippines Manila S i r : This refers to your letter dated June 21, 1968 to the Regional Director, Revenue Region No. 6, Quezon City, requesting reconsideration of his ruling denying your request for exemption from amusement tax on the admission fees collected during the championship games between the YCO and Mariwasa teams held at the Araneta Coliseum on June 23, 27 & 30, 1968. It appears that the basketball game was held by the Manila Industrial and Commercial Athletic Association (MICAA) which is an affiliate member of the Basketball Association of the Philippines which in turn is the National Sports' Association for Basketball under the Philippine Amateur Athletic Federation (PAAF). Under Section 22 of Republic Act No. 3135 which is quoted hereunder as follows: "Sec. 22. Exemption of income and properties from taxes . Any laws to the contrary notwithstanding, all income, properties, and importation of sports equipment and materials by the Philippine Amateur Athletic Federation and the members shall be exempt from amusement, real property, specific taxes and all other taxes and duties; Provided, however, That the sports equipment and material imported therein shall be for the exclusive use of the federation, the associations and their athletic members and are not to be disposed of for commercial purposes or for profit." the MICAA is considered a member of the PAAF and, therefore, falls within the exemption provided therein. In view thereof, your request in behalf of the MICAA for exemption from payment of the amusement tax is hereby granted. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue