BIR Ruling No. 025-64
BIR Ruling No. 025-64 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Apr 27, 1964
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April 27, 1964 BIR RULING NO. 025-64 6th Indorsement Returned to the Regional Director, B.I.R. Regional District No. 7, San Pablo City, the within papers bearing on the internal revenue cases of Messrs. Leonardo Paglinawan and Graciano Ruz, both of 215 of Crossing, Sta. Maria, Calauag, Quezon, with the following comment and information. LLjur In an investigation conducted by Agents of that Regional Office, it was ascertained that the above-named persons entered into "pacquiao contracts" with the Southern Luzon Irrigation Region, Bureau of Public Works, Lucena City. By virtue of said Agreements, they are considered independent contractors within the purview of Section 191 of the Tax Code. (Rafael Gerona vs. C.I.R., CTA Case No. 203, prom. March 30, 1959). Therefore, the gross receipts derived therefrom are subject to 3% tax imposed by the aforesaid section of the Code. cdll (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue
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