BIR Ruling

January 5, 1972 Messrs. Carlos J. Valdez & Co. Certified Public Accountants 1130 Perez St., Paco Manila Gentlemen : This refers to your letter dated December 20, 1970 requesting opinion as to whether or not the management fees received by your client, a financing company which is acting as manager of several financing companies, is subject to the 3% contractor's tax. In reply, I have the honor to inform you that for acting as manager of several financing companies, your client is subject to the contractor's fixed and percentage taxes prescribed by Sections 182(A)(1) and 191 of the Tax Code, the percentage tax to be based on its gross management fees received. Likewise, your client, as a finance company, is subject to the fixed and percentage taxes imposed by Section 182(A)(3)(gg) and 249-A of the Tax Code. cdtech Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue