BIR Ruling No. 084-82
BIR Ruling No. 084-82 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Mar 5, 1982
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March 5, 1982 BIR RULING NO. 084-82 53-f 22-81 84-82 University of the Philippines Health Sciences Center Philippine General Hospital M a n i l a Attention: Gloria T . Aragon, M . D . Directress Gentlemen : This refers to your letter dated July 30, 1981 requesting a ruling on whether your rental payments to Vacuum Finance Corporation are subject to the expanded withholding tax. You have represented that by virtue of a lease of agreement, the Philippine General Hospital is paying a monthly rental of P13,168.50 for the use of the said air-conditioning units to Vacuum Finance Corporation; and that you have been withholding a 5% tax from the said rental payments but that the said leasing firm is now strongly contesting the legality of the said 5% withholding tax. In reply, please be informed that since your rental payment is required to be made as a condition to the continued use of the air-conditioning units which are considered personal properties and considering also that you gross monthly rental payment exceeds P500.00, accordance with Section 1 (c) of Revenue Regulations No. 13-78, as amended by Revenue Regulations No. 6-79, implementing Presidential Decree No. 1351, now Section 53(f) of the Tax Code. Very truly yours, RUBEN B. ANCHETA Acting Commissioner
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