BIR Ruling No. 007-62

January 10, 1962 BIR RULING NO. 007-62 Tengtio & Tengtio Certified Public Accountants Rm. 302 Shurdut Bldg., Muralla St. M a n i l a Gentlemen : Reference is made to your letter dated April 24, 1961, requesting an opinion on the following case: cdtech "Corporation X was incorporated in the Philippines with principal offices in its incorporation papers at Manila. Its principal business at the beginning was purely trading in nature. The corporation subsequently started a manufacturing division with the factory located at Quezon City. "Question: 1. Is it necessary for the corporation to register its trade name under the provision of Section 203 of the Internal Revenue Code again at Quezon City, there being a previous registration at Manila and no change in the address of its principal office at Manila? 2. Invoice used by the corporation are registered at Manila. May these invoices be used in Quezon City when sales are transacted in Quezon City? Or is it necessary that in a new set of invoices be registered in Quezon City for sales in that city, bearing in mind the fact that all such sales in Quezon City will subsequently be entered in the general ledger kept in its principal office at Manila, where accounting records are kept in compliance with internal revenue regulations and law. Is it not that registration of sales invoice in one particular regional district constitutes registration for the whole country, as is the case for instance of invoice issued by travelling salesmen or peddlers. 3. The corporation plans to keep a net of books of accounts for the factory (what is known in accounting as a factory ledger) that will be posted to the general ledger at its principal office of business at Manila. The factory ledger therefore is of the nature of a subsidiary ledger only. Because of its principal office of business under its incorporation papers is in Manila, it is planned to have this factory ledger registered in Manila and for further reason of centralizing registration of all accounting books, invoices and all records in one regional office only. It is correct to register such books in Manila and no in Quezon City? Is registration in one regional district sufficient for the whole country? 4. For purpose of reporting and paying percentage taxes on sales, is it correct to render such report and payment in Manila for the combined sales of Manila and Quezon City? In reply thereto, I have the honor to inform you that: 1. Sales being made also in Quezon City, the factory is deemed a separated business establishment and, therefore, must be provided with a separate C-14 privilege tax receipt. It must also register separately in Quezon City for purposes of Section 203 of the Tax Code. 2. Sales invoices registered by the corporation in Manila may be superimposed with address in Quezon City when used in the latter city. 3. While the controlling books are kept in Manila and registered therein, the factory in Quezon City must keep such books and records as would clearly reflect all the transactions effected therein. All such records, such as the subsidiary ledger mentioned by you should be registered in Quezon City. prcd 4. All sales in Manila and Quezon City may be consolidated and returned for the percentage tax by the main office in Manila. Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue