BIR Ruling No. 065-62

March 28, 1962 BIR RULING NO. 065-62 The Regional Director BIR Regional District No. 8 Iloilo City S i r : Reference is made to the letter of Collection Agent Emiliano Y. Fernandez, which was referred to this Office in your 1st indorsement dated November 10, 1961. According to Mr. Fernandez, a "wirecasting" station, unlike a radio station, uses direct wire connections from the station to outside loudspeaker outlets paid by regular subscribers. Such being the case, and considering that tax-exemption status are construed strictly against the taxpayer and in favor of the government, this Office is of the opinion and so holds that so-called wirecasting stations are not embraced within the purview of Republic Act No. 2889 which exempts radio broadcasting and television stations from the franchise and privilege taxes. "Wirecasting" stations are considered independent contractors subject to the fixed and percentage taxes prescribed in sections 182(A)(1) and 191 of the Tax Code and, therefore, should be treated like other taxpayers with respect to registration, keeping of books of accounts and the issuance of invoices or receipts. cdtech Be guided accordingly. Very truly yours, BENEDICTO PADILLA Acting Commissioner of Internal Revenue