BIR Ruling

July 10, 1970 The Regional Director Revenue Region No. 6 Quezon City S i r : This refers to your telegram dated April 3, 1970 stated as follows: "CITY VICE MAYOR LILIANO NERI PRISAA GOVERNOR MADE REPRESENTATION THIS OFFICE REQUESTING EXEMPTION AMUSEMENT TAX PRISAA MEET PLEASE WIRE REPLY." In reply, I regret to inform you that the request made in behalf of the Private Schools Athletic Association, (hereinafter referred to as PRISAA), cannot be granted for lack of legal basis. Under Section 261 of the Tax Code, the 50% exemption from the amusement taxes imposed in Section 260 of the same Code, as amended by Republic Act No. 6110, is granted only to duly registered charitable institutions or associations. Since there is no showing that the PRISAA is such an association, it is subject to the payment of the amusement tax on the admission fees to the aforesaid PRISAA meet. Moreover, Republic Act No. 1284, which took effect on June 14, 1955, exempts only from amusement tax athletic meets conducted by public schools, provided further that the net proceeds therefrom shall accrue to the athletic fund or library fund of the school. cdta Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue