Taxability of a Common Carrier

October 24, 1966 BIR RULING NO. 045-66 Mr. Alberto C. Lavides Certified Public Accountant 52 Merchant St., Lucena City S i r : This refers to your letter dated August 17, 1966 stating the following: "My client is engaged in the business of a common carrier. As such, we are subject to the privilege tax provided for in Section 192 of the National Internal Revenue Code. cd "My problem is with reference to the provisions of Section 182(A)(2) which seems to state that a common carrier is also subject to the fixed annual tax based on its gross annual sales inasmuch as the types of business exempted from this subsection are those which are covered by Section 184, 185 and 186." In reply, I have the honor to inform you that an operator of a common carrier is subject to the annual fixed tax of P20.00 and to the percentage tax of 2% of his gross receipts pursuant to Sections 182(A)(1) and 192, respectively of the Tax Code. When a business is subject to the annual fixed tax, under Section 182(A)(1) of the Tax Code, it is no longer subject to the graduated annual fixed tax prescribed in Section 182(A)(2) of the same Code. LLphil Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue