BIR Ruling

April 2, 1973 Dr. Delfin C. Cruz, M.D. Director Mary Immaculate Hospital E. Rodriguez Avenue Pasig, Rizal S i r : This refers to your letter of even date requesting information as to the status of hospitals for internal revenue purposes prior to Presidential Decree No. 69. In reply, I have the honor to inform you that hospitals became liable to the contractor's fixed and percentage taxes beginning January 1, 1973 when the amendments to Title V of the Tax Code effected by Presidential Decree No. 69 took effect. The liability of hospitals to the contractor's fixed and percentage taxes was brought about by the insertion of the definition of the term "independent contractor'' to Section 191 of the Tax Code. Prior to January 31, 1973, hospitals were not subjected to the contractor's fixed and percentage taxes prescribed by Section 182(A) and 191 of the Tax Code. cdta Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue