BIR Ruling

June 8, 1976 Mr. Romulo P. de Villa Vice-Pres. & General Manager Spectrons Educational Systems, Inc. 3rd Floor, Villonco Building 219 Buendia Ave.,Makati, Rizal S i r : This refers to your letter dated March 8, 1976 requesting advice on the taxes that may be due from Spectron Educational Systems, Inc. under the following facts: The said corporation, a domestic corporation duly organized under and by virtue of Philippine laws, is engaged in the business of administering seminars on various skills for a fee. In order to add efficiency and effectivity to its training program, the corporation provides seminar participants with trainee kits, consisting of printed materials. And to further increase the efficiency of its program, the corporation will use training films which it will import from Australia and which it intends to lease to the public for a fee. In reply, I have the honor to inform you that the training films to be imported by that Company are educational films or those used for visual education within the purview of Section 146 of the Tax Code, and therefore, exempt from the specific tax therein prescribed. However, the imported training films are subject to the 7% compensating tax prescribed in Section 190 in relation to Section 186, both of the Tax Code. Moreover, for leasing training films, your company is considered a lessor of personal property, subject to the P50.00 annual fixed tax prescribed in Section 182(A)(1) of the Tax Code, and to the 3% tax on its gross receipts, pursuant to Section 191 of the same Code. Very truly yours, EFREN I. PLANA Acting Commissioner of Internal Revenue TAN-1456-040-3 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."