BIR Ruling

December 15, 1970 Mr. Leocadio A. Mauricio Certified Public Accountant San Beda College, Manila S i r : This refers to your letter requesting information as to the classification for tax purposes of Cinematica Services, whose business activities are described as follows: "1. Cinematica Services is primarily engaged in photography, developing and printing 16 MM films (black and white) or 35 MM color; "2. Advertising agencies, business firms and/or private individuals request Cinematica Services to photograph and develop their films for a fee based on above services as rendered. The black and white films are developed in the company's laboratory while k the color films are shipped to an Australian film laboratory for color developing and printing since the company does not have the facilities for the same." In reply, I have the honor to inform you that by the nature of the business activities of Cinematica Services, it is a photographic studio and, therefore, subject to the 3% tax on its gross receipts pursuant to Section 191(13) of the Tax Code, as amended by Republic Act No. 6110. Very truly yours , MISAEL P . VERA Commissioner of Internal Revenue