BIR Ruling

October 4, 1971 Mr. Rufino G. Fulgencio 134 J. Ruiz, San Juan Rizal S i r : This refers to your letter dated June 30, 1971, requesting opinion as to whether or not a common carrier who places advertising sign on his vehicles and collects a fee for them is liable for payment of additional taxes aside from the taxes he pays as a common carrier. In reply, I have the honor to inform you that the mere placing of advertising signs on the common carrier's vehicles will not render the carrier liable for the 3% contractor's tax prescribed in Section 191 of the Tax Code, as amended, considering that the placing of such advertising signs on the vehicles or buses of the carrier is but incidental to the common carriers business. However, the fees collected by the common carrier for placing advertising signs on his vehicles are subject to the income and residence taxes. aisa dc Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue