BIR Ruling No. 034-65

May 3, 1965 BIR RULING NO. 034-65 Mr. George T. Yap Culasi, Roxas City S i r : This refers to your letter dated June 24, 1963 requesting information regarding your tax liabilities for operating the so-called "Shell reforwarding bodega" in that City. In reply, I have the honor to inform you that in an investigation conducted by agents of this Office, it was ascertained that you received Shell petroleum products for the purpose of delivering them to different Shell dealers and customers upon prior advice from Shell Company; that these petroleum products are stored in your bodega which you personally maintain and operate; that you are responsible for the employment and payment of the salaries of the necessary personnel in the operation of the bodega, and that for services rendered, Shell Company pays you a monthly operating fee of P1,450.00 plus one-fourth () centavo allowance for every liter of Shell petroleum products coursed thru your reforwarding bodega. From the foregoing facts, this office is of the opinion and so holds that the business which you are engaged in is that of a warehouseman subject to the fixed annual tax of P20.00 and to the 3% tax prescribed by Sections 182(A)(1) and 191 of the Tax Code. prcd Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue