Exemption from Withholding Tax — PLDT Payments

April 1, 1981 BIR RULING NO. 063-81 053-f 000-00 063-81 Bengzon, Zarraga, Narciso Gudala, Pacson, Azcuna and Bengson Sol Building, Amorsolo St. Legaspi Village, Makati Attention: Atty . Amando V . Faustino, Jr . Gentlemen : This refers to your letter dated September 3, 1980 requesting a ruling as to whether or not the payments to be made by the Philippine Long Distance Telephone Company (PLDT) in favor of your client, Integrated Health Care Services, Inc. (Intercare) are subject to the expanded withholding tax provisions of Revenue Regulations No. 6-79 implementing Presidential Decree No. 1351. It is represented that PLDT and Intercare had entered into a contract whereby the latter undertook to provide health care services for PLDT employees such as medical, surgical and hospitalization services, the operation of the company clinics and the supply of its basic medicines. In reply thereto, I have the honor to inform you that under the aforesaid Regulations, payments only to persons enumerated therein are subject to withholding tax. Since payments made by PLDT in favor of Intercare for health care services are not among those specified in the Regulations, PLDT is not subject to the withholding tax. Very truly yours, RUBEN B. ANCHETA Acting Commissioner