BIR Ruling No. 040-62

February 6, 1962 BIR RULING NO. 040-62 The Medical Director Manila Railroad Company Hospital Caimito Road, Caloocan Rizal S i r : Reference is made to your letter dated April 29, 1961, requesting for and behalf of the doctors and pharmacists employed in that hospital, exemption from the occupation tax (D) and the privilege tax for dispensing, giving away or administering any narcotic drugs (S). You also inquired whether or not the nurses employed therein are subject to the occupation tax. In answer thereto, I have the honor to inform you that the doctors, pharmacists and nurses employed in government-owned and controlled corporations, like the Manila Railroad Co., do not come within the purview of "persons employed in any branch of the service of the Government of the Philippines . . .". Under section 182(C)(7) of the Revenue Code who are exempt from the occupation tax imposed in section 182(B) thereof. Accordingly, said professionals are subject to the occupation tax. Neither do the above-mentioned doctors and pharmacists fall within the provisions of section 58 of Revenue Regulations No. V-38, exempting "officials and employees of the national, provincial city or municipal governments or any political sub-division thereof . . ." from providing themselves with the Schedule S tax receipts. cdtech Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue