Exemption from Withholding Tax — Retainer Fees

July 5, 1979 BIR RULING NO. 055-79 Exemption from withholding tax retainer fees In reply to your letter dated December 4, 1978, I have the honor to inform you that the withholding tax provisions of Revenue Regulations No. 13-78 implementing Presidential Decree No. 1351, particularly Sections 1 (a)(1) and (b) thereof apply only to professionals who are individually engaged in the practice of professions and to taxable juridical persons. Since the retainer fees are being paid by you not to lawyers who are individually engaged in the practice of their profession but to law offices which are duly registered professional partnerships and considering further that said partnerships are non-taxable juridical entities, the retainer fees paid to such partnerships are not subject to the withholding tax prescribed by said regulations. aisa dc