BIR Ruling

October 5, 1970 Arturo A. Alafriz & Associated 7th Floor, Metropolitan Bank Bldg. Ayala Avenue, Makati, Rizal Attention: Atty . Narciso A . Tadeo Gentlemen : This refers to your letter of September 21, 1970 requesting information as to whether or not your client, the Philippine Iron Mines, Inc., may be allowed to continue paying its income taxes (100%) at Larap, Jose Panganiban, Camarines Norte where it is carrying on its mining operations. In reply, I have the honor to inform you that pursuant to Revenue Memorandum Circular No. 19-66 dated April 11, 1966, implementing Section 46 of the Tax Code, a corporation, partnership or association should file its income tax return with, and pay the income tax due from it, to the Collection Agent of the city or municipality where the principal office of its business is located and its books of accounts are kept. According to your representative, the books of accounts of Philippine Iron Mines, Inc. are kept at its office at Larap, Jose Panganiban, and that its office in Manila is maintained merely for purposes of administration. Based on the above representations, this Office believes and so holds that your client should file its income tax returns and pay the income taxes due from it at Larap, Jose Panganiban. It may also be stated in this connection that if your client has branches or factories in cities and/or municipalities other than Larap, Jose Panganiban, it is given the option to apportion the second installment among such cities and/or municipalities where it has branches or factories. Very truly yours, CONRADO P. DIAZ Acting Commissioner of Internal Revenue