BIR Ruling

August 12, 1969 June Pajo Promotions R-208 El Hogar Filipino Building Juan Luna, Manila Attention: Mr . Jun P . Pajo Executive Producer Gentlemen : This refers to your letter dated August 11, 1969 requesting exemption from the payment of the amusement tax on the admission fees to the stage-musical presentation of "1969 MUSICAL & FASHION FESTIVAL" to be held at the Rizal Memorial Coliseum on August 24-25, 1969, under the provisions of Republic Act No. 722. llcd In reply, I have the honor to inform you that the intention of Congress in enacting Republic Act No. 722 is stated clearly in the explanatory note to H.B. No. 2775, the pertinent portion of which reads as follows: " In order to encourage the promotion and development of high class music in the Philippines, it is proposed in this bill that the admission fees or charges collected for the holding or staging of operas, symphonies and other musical concerts be exempted from the payment of taxes. " It is rather paradoxical that most Filipinos, lovers of good music as they are, the popular tunes appeal to them more than the classical opus by the old masters." (Emphasis supplied). A scrutiny of the program submitted discloses that the presentation is definitely not of the class contemplated by the aforesaid Act as expounded in the explanatory note to H.B. No. 2775. The participants are top singers of radio and television who undoubtedly specialize in the singing of popular tunes, the fashion show being merely a display of the latest in fashion cannot be considered cultural and other numbers of the program are ordinary stage performance. prcd In view of the foregoing, it is the opinion of this Office, as it hereby holds, that the admission fees to the presentation in question are subject to the amusement tax. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue