BIR Ruling

August 14, 1973 Mr. Reynaldo T. Teo Certified Public Accountant P.O. Box 5, Sanchez St. Jolo, Sulu S i r : This refers to your letter dated May 8, 1973 requesting information whether or not a private hospital whose aim is for profit is subject to tax under Section 182 of the Tax Code and other internal revenue taxes. In reply, I have the honor to inform you that the previous rulings of this Office holding that hospitals fall within the purview of the term "independent contractors" under Section 191 of the Tax Code, as amended by Presidential Decree No. 69 and, therefore, subject to the contractor's fixed and percentage taxes under Section 182 (A)(1) and 191, respectively, both of the Tax Code, have been revoked and superseded by the ruling of this Office dated June 20, 1973. Such being the case, hospitals, whether or not established for profit, are not subject to the said taxes. cdtech 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"