BIR Ruling

February 11, 1970 Mr. Isabelo F. Magalit Varsity Christian Fellowship of the Philippines P.O. Box 2094, Manila S i r : This refers to your letter dated January 20, 1970 stating the following: "I am a physician by training, and passed the Civil Service Board Examination for Physicians in November 1964. However, since graduation from the UP Medical school I have been a member of the staff of the Inter-Varsity Christian Fellowship of the Philippines. I am working as a full time student evangelist, and have no medical practice at all. However, I still register with the Civil Service Commission every year. casia Should I be included among those exempted from paying the privilege fee?" In reply thereto, I have the honor to inform you that under the foregoing circumstances, you are not subject to pay the occupation tax imposed in Section 182(B) (1) (a) of the Tax Code as amended by Republic Act No. 6110. The fact of being a professional should be coupled with the actual act of professional practice in order to render a professional liable to the tax for it is the essence of the occupation tax to tax the professional act and not the mere fact of being a professional. Very truly yours, MISAEL P. VERA Commissioner of Internal Revenue