10% Withholding Tax "Royalties in Any Form"

May 7, 1980 BIR RULING NO. 043-80 Mr. Bruno C. Rodriguez 51 San Antonio Street San Francisco del Monte Quezon City S i r : This refers to your letters dated November 26 and 30, 1979, inquiring whether the payments made to you as owner of Silica Mining claim in Roxas, Palawan by Vulcan Industrial and Mining Corporation (hereinafter referred to as Vulcan), as operator thereof are covered by the Expanded Withholding Tax System. In reply, please be informed that the payment made to you by Vulcan in the amount of P3.00 per metric ton of silica extracted are not covered by the Expanded Withholding Tax System under Revenue Regulations No. 13-78 as amended by Revenue Regulations No. 6-79, implementing Presidential Decree No. 1351. However, said payments fall within the purview of "royalties in any form"; hence, are subject to the 10% withholding tax prescribed by Section 53(c) of the Tax Code of 1977, as amended. cdta Very truly yours, RUBEN B. ANCHETA Deputy Commissioner