BIR Ruling

November 24, 1970 The President U. P. Lawyers' Circle (WILOCI) Rm. 330 Natividad Building Escolta, Manila M a d a m : This refers to your letter dated November 12, 1970 requesting tax exemption for donations which you would receive in connection with your Invitational Premiere of "Macho Callahan" to be shown at the Forum Theater on December 2, 1970, the proceeds of which will be used to maintain your WILOCI Legal Consultation Center which services for free the legal needs of destitute litigants who seek your assistance. It appears that admission to the aforesaid invitational show is be means of an invitation card issued to patrons and that no free or charge is indicated therein. Section 260 of the Tax Code, as amended by Republic Act No. 6110, provides that the rate of 20% when the amount paid for admission is P1.00 or less and 30% when the amount paid for admission exceeds P1.00 shall be collected from the proprietor, lessee, or operator of theaters, cinematographs, concert halls, circuses and other placement of amusement. Considering that no amount is paid for admission to the invitational show as shown in the invitation card issued to the patrons and considering further that the donations given in consideration of the purposes and objectives of the WILOCI is on a voluntary basis the same is not subject to amusement tax. In view thereof, this Office hereby grants your request. Very truly yours, CONRADO P. DIAZ Acting Commissioner of Internal Revenue