Director's Fees Received from Manila Bulletin Publishing Corporation Exempt from Expanded Withholding Tax

March 21, 1996 BIR RULING NO. 042-96 51 (f) 239-87 042-96 Justice Abraham F. Sarmiento 22 Sunrise Hill, New Manila Quezon City S i r : This refers to your letter dated February 22, 1996 requesting confirmation of your opinion to the effect that the director's fees you received from the Manila Bulletin Publishing Corporation as one of its Directors is exempt from the expanded withholding tax. In reply thereto, please be informed that your opinion is hereby confirmed. Pursuant to Revenue Regulations No. 6-85 implementing Section 51(f) of the Tax Code, as amended, otherwise known as the Revised and Consolidated Expanded Withholding Tax Regulations, payments only to persons enumerated therein are subject to the expanded withholding tax. To date, several provisions of said Regulations have been amended but inclusion of director's fees is not one of them. Such being the case, BIR Ruling No. 239-87 dated August 11, 1987 is still in force and effect. Accordingly, since director's fees is not among those specified in said Regulations, the amount you received from the Manila Bulletin Publishing Corporation is not, therefore, subject to the expanded withholding tax. However, the payor shall render an information return on such payment pursuant to Section 71 of the Tax Code, as amended by Batas Pambansa Blg. 135 and as implemented by Section 21 of Revenue Regulations No. 1-82 dated March 18, 1982. aisadc Very truly yours, LIWAYWAY VINZONS-CHATO Commissioner of Internal Revenue