BIR Ruling No. 041-80

October 27, 1980 BIR RULING NO. 041-80 187-t 623-58 41-80 Kammer Marketing Factor, Inc. Room 403 Araza Bldg., Paseo de Roxas Makati, Metro Manila Attention : Ms . Gigi Borromeo Vice-President/General Manager Gentlemen: This refers to your letters dated June 26, 1980 and July 21, 1980, informing this Office that you deal primarily in the solicitation of subscriptions for various magazines; that the subscriptions solicited are sent directly to the publisher which, in turn, sends the subscribed magazines directly to the subscribers. In reply, I have the honor to inform you that "subscription" means a purchase by prepayment of the future issues of a periodical usually for a fixed period. (Webster's Third New International Dictionary, p. 2278) Consequently, when you solicit subscriptions for magazines, you actually bring about sales or purchases of merchandise for other persons or bring proposed buyers and sellers together; hence, you are a commercial broker within the purview of Section 187(t) of the Tax Code of 1977, as amended. Accordingly, you are subject to the annual fixed tax of P1,000 and to the 6% tax on your gross compensation pursuant to Sections 192(3)(bb) and 208 of the same Code. cdta Very truly yours, ROMULO M. VILLA Acting Commissioner