BIR Ruling No. 067-65

June 18, 1965 BIR RULING NO. 067-65 Mr. Roque B. Neri, Jr. 838-G P. Leoncio St. M a n i l a S i r : This refers to your letter dated May 14, 1965 stating as follows: "'X' Company will employ on a salary basis more than one registered licensed optometrists; that it will provide them with complete apparatus and equipment, necessary clinic with laboratory for the exercise of their profession; that the said optometrists will receive patients for eye examination, giving them prescription in the form of correctional lenses and supplying them with the lenses; that said optometrists will also prepare correctional lenses in accordance with the prescriptions issued to patients; that said optometrists will likewise receive and prepare correctional lenses in compliance with the prescriptions of other optometrists for the patients of the latter; and that the money received for the services of the optometrists and the disbursements made in connection thereof shall be treated or made in the receipts or income of "X" Company." You now request information as to the tax consequences of the foregoing set-up. In answer thereto, I have the honor to inform you that, based on the facts presented, "X" Company is considered a manufacturer subject to the fixed and percentage taxes prescribed by Sections 182(A)(1) and 186 of the Tax Code. On the other hand, the optometrists employed by "X" Company are subject to the occupation tax prescribed by Section 182 of the Tax Code. Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue