BIR Ruling No. 081-63

November 4, 1963 BIR RULING NO. 081-63 The Manager Pioneer Song Lyric Publications, Inc. P. O. box 1309 Manila S i r : I have the honor to acknowledge the receipt of two (2) copies of your song publications entitled "Philippine Pioneer Song Hits" and "The Latest Song Hits". cdta We examined very carefully the two publications and we observed that, while it may be true that they may approximate a magazine in form, nevertheless they cannot qualify as magazines in substance within the exemption provisions of Section 191 of the Tax Code. Even in form, they are more or less more pamphlets or handbooks of song hits. In view of the foregoing, it is the opinion of this Office that as publishers of said publications you are subject to the 3% tax prescribed in Section 191 of the Tax Code. You are, therefore, advised to consider our previous ruling dated May 21, 1955 as superseded. As regards your claim for exemption from the compensating tax, it may be stated that even publishers falling within the exemption provisions of Section 191 of the Tax Code are subject to said tax on their importation of articles for use in their business. cdti Very truly yours, (SGD.) RAMON T. OBEN Acting Commissioner of Internal Revenue