BIR Ruling

August 27, 1971 Angela Management & Trading Corporation P. O. Box 435, Makati Commercial Center Makati, Rizal Attention: Mr . Romulo A . Guanzon Gentlemen : This refers to your letter dated August 10, 1971 requesting information as to what category your corporation would fall for privilege tax purposes. It is stated that the primary purpose of your corporation is "To take over, conduct and/or manage the whole or any part of the rights, assets, business and property of any person, firm, association, partnership, syndicate or corporation, in so far so the law may allow, and to exercise all the powers necessary, or convenience in and about the conduct and management of the same; to perform financing and/or management services, including financing and management counselling provided, however, that it will not include management of funds, securities portfolios or similar assets of these corporations and entities." cdt In reply, I have the honor to inform you that based on the primary purpose of your duly approved and registered Articles of Incorporation, your Corporation is considered a management corporation subject to the annual fixed tax of P50.00 and to the 3% contractor's tax on its gross monthly receipts pursuant to Sections 182(A)(1) and 191(18) of the Tax Code, as amended by Republic Act No. 6110. The foregoing ruling, however, is subject to modification, should it be ascertained after investigation of your actual business operation that you are engaged in other business which are subject to internal revenue taxes prescribed in the Tax Code or other revenue laws. Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue