BIR Ruling

January 18, 1967 Mr. Fidel R. Sacdalan Certified Public Accountant Suite 714 Bank of P.I. Bldg. Plaza Cervantes, Manila S i r : This refers to your letter dated January 14, 1967 requesting information as to what internal revenue taxes a corporation shall be liable to, if it engages in business in accordance with the following primary purpose: prll "To engage in industrial design work and consultation service, planning, engineering, market research, development and implementation of products both consumer and industrial, physical and graphic packing, visual merchandising and promotion displays, corporate image and identification and the promotion of sales and distribution of products. To deal in all the physical aspects and properties of a company whereby public goodwill is influence visually such as trademarks, tradenames, company and trade signs, office forms and such other undertaking which would create and develop a recognizable identity or company personality which inspires public confidence and friendship." In reply, I have the honor to inform you that if the corporation engages in industrial design work and consultation service, planning, engineering, market research, development and implementation of products both consumer and industrial, it is a contractor, subject to the fixed annual of P20.00 and to the 3% tax on gross receipts, pursuant to Sections 182(A)(1) and 191 of the Tax Code. If it engages in visual merchandising and promotion displays, corporate image and identification and the promotion of sales and distribution of products and deal in all the physical aspects and properties of a company whereby public goodwill is influenced visually such as trademarks, tradenames, company and trade signs, office forms and such other undertaking which would create and develop a recognizable identity or company personality which inspires public confidence and friendship, it is a business agent, subject to the annual fixed tax of P75.00 and to the 3% tax on gross receipts, prescribed by Sections 182(A)(B)(w) and 191 of the Tax Code. LLpr The corporation is also subject to the income and additional residence taxes. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue