3% Withholding Tax — Income Payments to Disneyland Landscaper

May 13, 1980 BIR RULING NO. 057-80 Disneyland Landscaper 80 Dolores Homesite San Fernando, Pampanga Attention: Mr . Andres M . David General Manager Gentlemen : This is in reply to your letter dated February 16, 1979 requesting a ruling whether the income payments to Disneyland Landscaper by Westinghouse International Projects Co. for the lawn/garden maintenance and trash collection of its residential units inside the NPC Housing Village in Bagac, Bataan are subject to the withholding tax provisions of Revenue Regulations No. 13-78 as amended by Revenue Regulations No. 6-79 both implementing Presidential Decree No. 1351. Under Section 1(e)(2)[q and r] of Revenue Regulations No. 6-79, which took effect on July 1, 1979, persons engaged in landscaping and interior decoration services and persons engaged in the collection and disposal of garbage are subject to the withholding tax of 3% of 15% of their gross payments. Such being the case, beginning July 1, 1979, gross payments received by the Disneyland Landscaper from the Westinghouse International Projects Co. for lawn/garden maintenance and trash collection of the residential units inside the NPC Housing Village in Bagac, Bataan are subject to the 3% withholding tax on 15% thereof. Beginning November 1, 1978, the effectivity date of Revenue Regulations No. 13-78 up to June 30, 1979, said gross payments were not subject to withholding tax. Very truly yours, EFREN I. PLANA Acting Commissioner