BIR Ruling
BIR Ruling • Bureau of Internal Revenue (BIR) Issuances • Rulings (Unnumbered) • Dec 8, 1972
Full text
December 8, 1972 The National Power Corporation 161 Bonifacio Drive Port Area, Manila Gentlemen : With reference to your letter dated November 29, 1972, I have the honor to inform you that, after a careful perusal of your contract with Gabriel P. Formoso and Associates this Office found that said contract involves purely the rendition of architectural services by said professional firm conformably with the definition of the "General Practice of Architecture" provided by Section 14 of Republic Act No. 545. In view of the foregoing, G.P. Formoso and Associates cannot be considered a contractor within the purview of Section 191 of the Tax Code and, therefore, the professional fee due said firm under your contract with it is not subject to the withholding provisions of Republic Act No. 1051. cdt Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue
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