BIR Ruling

October 24, 1973 Mr. Virgilio S. Baliola 881-3 Kundiman St. Sampaloc, Manila S i r : This refers to your letter dated September 6, 1973 requesting information as to whether or not you are subject to the withholding tax provisions under Section 54, in relation to Section 53, both of the Tax Code on your remittance, thru the First United Bank, of the U.S. dollars equivalent to the aggregate amount of P1,278.10 to Central Press Features, 80 Fleet Street, London EC4, representing payment of foreign articles that were published in local newspapers and magazines. In reply thereto, I have the honor to inform you in the negative. Your payment of the foreign articles purchased abroad is not considered income within the Philippines. Accordingly, the seller thereof which is not engaged in trade or business in the Philippines, is not subject to Philippines income tax. Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue TAN 1601-593-5 "TAXPAYERS SHOULD INDICATE THEIR TAN IN ALL COMMUNICATIONS TO THE BIR."