BIR Ruling

June 16, 1969 Rural Bank of Cadiz, Inc. Cadiz City, Negros Occidental Attention: Margarita H. Coscolluela President/Manager Gentlemen : This refers to your letter dated April 2, 1969 requesting information as to the tax status of the Rural Bank of Cadiz, Inc. in view of the passage of Republic Act No. 5431. In reply, I have the honor to inform you that Section 24 of the Tax Code as amended by Republic Act No. 5431 subjects all corporate taxpayers other than those exempted under subsection (c)(1) of Section 24 and Section 27 of the said Code to the Corporate income tax regardless of the provisions of existing special or general laws to the contrary. By virtue of the aforecited amendment, the only corporations, associations and organizations exempt from corporate income tax under the National Internal Revenue Code are the purely cooperative companies or associations as provided for under Section 24(c)(1) and the organizations specifically except under Section 27. All others, including those which under special laws are exempt are now subject to tax. In view of all the foregoing, this Office is of the opinion as it hereby holds that Republic Act No. 5431 has repealed the exemption previously enjoyed by your Rural Bank. Accordingly, the Rural Bank of Cadiz, Inc. is now required to file income tax returns, and is subject to the corporate income tax at the increased rates on income received or earned starting July 1, 1968. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue