BIR Ruling

December 22, 1970 Ambassador Jose S. Laurel III Embassy of the Philippines Tokyo, Japan S i r : This refers to your letter dated September 14, 1970 to the Honorable, the Secretary of Foreign Affairs, Manila bearing on Note No. 1058/D5b dated September 1, 1970 from the Royal Greek Embassy in Tokyo requesting information on taxes payable by foreign artistic groups going to the Philippines. In reply, I have the honor to inform you that if the foreign artistic groups shall hold only musical programs, operas, concerts, recitals, dramas or art exhibitions where the exhibitions or performances have for their primary purpose the propagation and development of art and culture of a foreign country and that the element of profit is only incidental, the admission fees to be derived therefrom are exempt from the amusement tax, pursuant to Section 260 of the Tax Code as amended by Republic Act No. 6110. aisadc However, the individual performers constituting the foreign artistic groups are subject to Philippine income tax on the compensation they received which is considered income derived from sources within the Philippines. Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue