BIR Ruling

November 10, 1971 Miss Aida R. Gonzaga 1704 Baler Street Makati, Rizal M a d a m : This refers to your letter dated October 20, 1971 requesting information whether under the following illustration, "A" as a general agent is subject to fixed and percentage taxes: aisa dc "A" is a company who is a General Agent of 'XYZ Co.', a non-life insurance company. As a General Agent for non-life insurance, 'A' receives income in the form of commission from 'XYZ Co.' It is also verbally represented that "A" Co. renders collection services for XYZ Co on unpaid premiums and also renders related services. In reply, I have the honor to inform you that under the foregoing circumstances, "A" is considered an independent contractor subject to the annual fixed tax of P50.00 and to the 3% tax, in accordance with Sections 182(A)(1) and 191(18) of the Tax Code, as amended by Republic Act No. 6110. "A", under the foregoing facts, is not a broker within the purview of Section 194(t) of the Tax Code. acd Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue