BIR Ruling

March 29, 1976 Mr. Bienvenido J. Cagara Sacris Village Mandawe City S i r : In reply to your letter dated March 1, 1976, I have the honor to inform you that a corporation engaged in the business as a Naval Architect and Load Line Surveying of Inter-Island vessels without employing marine engineers except experienced marine surveyors and a licensed Naval Architect as Consultant falls within the purview of the term "independent contractor" under Section 191 of the Tax Code, as amended by Presidential Decree No. 69 and, therefore, subject to the fixed annual tax of P50.00 prescribed in Section 182(A)(1) of the Tax Code and its gross receipts are subject to the 3% contractors tax prescribed in Section 191 of the same Code. Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-1456-040-3