BIR Ruling

March 27, 1969 Mr. Narciso Alegre Pest Control Association of the Philippines Public Relations Office P.O. Box 3477, Manila S i r : This refers to your letter dated March 11, 1969, requesting that tax exemption be granted to all members of the Pest Control Association of the Philippines. In reply, I regret to inform you that your request cannot be granted for lack of legal basis. All members of the aforesaid Association who are engaged in activities consisting of the extermination and control of pest to life, property and crops are considered independent contractors, subject to the annual fixed tax of P20.00 and to the 3% tax prescribed by Sections 182 and 191, respectively, of the Tax Code. (B.I.R. Rulings dated September 15, 1956, April 2, 1957 and September 6, 1957) In this connection, it may be stated that tax exemption is a matter of legislative grace. An exemption from the common burden cannot be permitted to exist upon vague implication. lexlib Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue