Sales Branches Distinct from Main Office for Purposes of the Fixed Annual Tax

April 15, 1977 BIR RULING NO. 002-77 Sales branches distinct from main office for purposes of the fixed annual tax This refers to your letter dated January 24, 1977 stating that your company is a manufacturer of fertilizer and agricultural chemicals; that your manufacturing plant is located at Limay, Bataan, while your principal office is found in Makati, Rizal; and that all your manufactured products are transported to various sales branches in different provinces where the products are sold to consumers. aisa dc Based on these representations you are requesting an opinion on whether your company is liable to pay only one fixed tax or as many fixed taxes as there are sales offices in different provinces where your products are sold. In reply, I have the honor to inform you that under Section 178 of the Tax Code, the fixed tax is payable for every separate or distinct establishment or place where business subject to tax is conducted. Accordingly, you are liable to pay the annual fixed tax of P50.00 as prescribed by Section 182(A)(1) of the Tax Code not only for your main office in Makati but also for every branch in different provinces where your products are sold. (Taligaman Lumber Co. vs. Collector, CTA Case No. 161, January 31, 1959, affirmed in G.R. No. L-15716, March 31, 1962; Arcega vs. Commissioner, CTA Case No. 574, October 30, 1964) cdt