BIR Ruling No. 020-63

March 22, 1963 BIR RULING NO. 020-63 The Philippine Education Company, Inc. P. O. Box 620, Manila Gentlemen : Reference is made to your letters dated February 4 & 13, 1963, requesting confirmation of your opinion that the shipment and distribution of Reader's Digest subscription copies under the following arrangement are exempt from the sales and compensating taxes. aisadc The Reader's Digest control office (printing and distributing for the South Pacific having recently transferred to Tokyo, Japan, individual magazine subscription copies will be shipped to Manila in bulk via freight from Japan, transferred to the Manila Post Office and mailed to the individual subscribers. Each copy will be already wrapped and addressed. That company will, however, receive the shipment and instruct the carrier to deliver or release it to the Post Office which subsequently bills the company for all postage due. You stated that for the undertaking the company received nothing, it being merely an act of accommodation to the publishers of Reader's Digest because you are the exclusive distributor of newstand copies of the magazine. As a matter of fact, you will be reimbursed only for expenses actually incurred and that is, for postage. You likewise stated that there is no exclusive subscription agent for the Reader's Digest, so much so that a subscription may either be sent direct to the publishers or processed by an authorized agent. The possibility of shipping the subscription copies with the news-stand copies is eliminated by the fact that the former will be transferred from the pier direct to the Post Office. Moreover, they are pre-wrapped and addressed. In answer thereto, I have the honor to inform you that, based on your representation that the copies are received only for mailing to the subscribers, this Office will authorize the release of the shipment free of tax provided that a list of the subscribers for every shipment is submitted to this Office. Very truly yours, (SGD.) JOSE B. LINGAD Acting Commissioner of Internal Revenue The above ruling was duly signed by the Acting Commissioner of Internal Revenue on March 22, 1963. (SGD.) P. F. LANDAS Revenue Operations Head (Legal)