BIR Ruling

August 8, 1968 Mr. Policarpio C. Tolentino 444 Isabel Street Sampaloc, Manila S i r : This refers to your letter dated July 18, 1968 requesting information as to the business tax liabilities of a corporation which intends to lease some of equipment, consisting of delivery trucks, tractors and machineries. In reply, I have the honor to inform you that if the corporation furnishes the operators, and/or drivers and fuels of the trucks, tractors and machineries leased, then the corporation is considered an independent contractor, subject to the annual fixed tax of P20.00 and to the 3% percentage tax prescribed in Sections 182 (A)(1) and 191 of the Tax Code, respectively. However, if the corporation merely leases the trucks, tractors and machineries without furnishing the operators, drivers and fuels of the equipment and machineries leased, then it is not subject to any internal revenue tax on business. iatdc Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue