BIR Ruling

February 26, 1970 Mr. Iluminado M. Icasas 2469 Zamora Street Pasay City S i r : This refers to your letter dated February 3, 1970 requesting information as to whether or not you are exempt from the payment of the professional tax. It is represented that you are a registered professional Electrical Engineer and Mechanical Plant Engineer; that presently, you are the General Manager of a company engaged in the manufacture of sewing machines and water pumps; and that your work is more on management and not on engineering as the company has a Professional Electrical Engineer and a Mechanical Plant Engineer who paid their respective occupation taxes. In reply, I have the honor to inform you that under the foregoing circumstances, you are subject to two occupation taxes corresponding to your two professions, as an Electrical Engineer and as a Mechanical Plant Engineer pursuant to Section 182(B) of the Tax Code, as amended by Republic Act No. 6110. The fact that the company is engaged in the manufacture of sewing machines and water pumps, management over the business affairs thereof requires the use or exercise of the knowledge of an electrical engineer and/or mechanical plant engineer. Hence, as a General Manager of such company, you are using or exercising your knowledge of your two professions. aisa dc It may be stated in this connection that a "general manager" of a corporation is "the person who really has the most general control over the affairs of a corporation and who has knowledge of all its business and property, and who can act in emergencies on' his own responsibility, and who may be considered the principal officer". (Stearns-Roger Mfg. Co. v. Aztec Gold Min. & Mill Co., Vol. 18 Words & Phrases, p. 418) Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue