BIR Ruling No. 085-64

December 29, 1964 BIR RULING NO. 085-64 The President & General Manager Yellow Ball Freight Lines, Inc. 9th Avenue, Grace Park Caloocan City S i r : Reference is made to your letter dated November 25, 1964 stating that you have a contract with the NAMARCO for trucking, handling and warehousing of its goods at the rate of P7.00 per so-called revenue ton broken down as follows: LexLib "Trucking P3.00 per Revenue Ton "Handling P1.50 per Revenue Ton "Warehousing P2.50 per Revenue Ton You now request information as to whether or not the NAMARCO should withhold a 3% tax on the total amount of P7.00 in making payments to you pursuant to Republic Act No. 1051. In answer thereto, I have the honor to inform you as follows: From your representation, you are clearly engaged in two lines of business, that is as transportation contractor and as warehousemen. As transportation contractor, your gross receipts are subject to 3% tax and as warehousemen your gross receipts are subject to 3% tax. From the figures presented, the indicated trucking fee of P3.00 and handling fee of P1.50 are considered your gross receipts from trucking subject to 3% withholding tax. On the other hand, the warehousing fee of P2.50 is subject to 3% withholding tax. LibLex Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue