BIR Ruling

January 22, 1974 Fortune Insurance & Surety Co., Inc. P. O. Box 3564, Manila Attention: Mr . Primo B . Domingo Production Service Manager Gentlemen : This refers to your letter dated December 29, 1973 requesting clarification whether your branch of ice in Legaspi City is subject to the annual fixed tax of P500.00 pursuant to Section 182(A)(3)(gg) of the Tax Code. cdta In reply, I have the honor to inform you that under Section 178 of the Tax Code, the tax on business is payable for every separate and distinct establishment or place where business subject to tax is conducted. This provisions contemplates a case where a person, firm or company who or which, although engaged in only one particular class of business, nevertheless, maintains two or more separate and distinct branches or establishments for the operation of said business, in which case, the fixed tax is imposed upon every separate and distinct branch or establishment where the business subject to tax is conducted. Therefore, every branch of ice of your company is subject to the annual fixed tax of P500.00 prescribed by Section 182(A)(3)(gg) of the Tax Code. acd Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN-1601-593-5 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."