BIR Ruling

July 27, 1967 Mr. Crescencio A. Toribio 356 Marcos A. Calo St., Butuan City S i r : This refers to your telegram dated June 28, 1967 requesting for the reconsideration of BIR Ruling dated May 4, 1967 which subjects the proposed ABC Company to the annual fixed tax of P20.00 prescribed in Section 182(A)(1) and to the 3% contractors tax prescribed in Section 191 both of the Tax Code. prll In reply, I have the honor to inform you that the services to be rendered by the ABC Company as represented in your letter dated March 22, 1967, falls squarely within the purview of independent contractor as contemplated by Republic Act No. 1612. The term "independent contractor" includes all persons whose activity consists essentially of the sale of all kinds of services for a fee. The official status of the individual person comprising the ABC Company which will engage in the sale of pilotage services is not considered in determining the nature of the services so rendered. There being no cogent reason to reconsider our ruling contained in our letter to you dated May 4, 1967, your request is hereby denied. LLpr Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue