BIR Ruling

March 30, 1976 Cultural Research Foundation, Inc . As A Withholding Agent Reference is made to your letter dated December 16, 1976, requesting opinion as to whether or not the artists fees paid by the Museo Committee on Performing Arts (MCPA),a committee of the Visayan Cultural Research Foundation, Inc.,to the Little Singers of Paris, is subject to income tax. In reply thereto, please be informed that since the said fees are paid by the MCPA in consideration for a series of performances in the Philippines, the same constitute income derived from Philippine sources. The said fees are subject to 30% withholding tax. Although the Visayan Cultural Research Foundation, Inc. is tax-exempt, it is constituted as a withholding agent under Section 53(b)(1) of the Tax Code because it has the control and custody of the performance fees payable to the Little Singers of Paris. cdasia