BIR Ruling

February 24, 1967 Mr. Juan P. Pavilando Certified Public Accountant 1065 P. Noval, Sampaloc Manila S i r : This refers to your letter dated December 12, 1966 requesting opinion on the following: "A domestic corporation, stocks of which is 99% owned by an American, acts as a representative of another domestic corporation bringing about sales to the U.S. Armed Forces within and without the Philippines. From the generated sales, the representative company earns commissions." In reply, I have the honor to inform you that under the foregoing facts, the domestic corporation is considered a commercial broker, subject to the commercial broker's fixed and percentage taxes prescribed by Section 182(A)(3)(s) and 195 of the Tax Code. aisadc Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue