BIR Ruling No. 087-61

April 4, 1961 BIR RULING NO. 087-61 The Benguet Consolidated, Inc. P.O. Box 817, Manila Gentlemen : Reference is made to your letter dated March 1, 1961, as supplemented by that dated March 13, 1961, requesting in effect information whether or not, on the basis of our letter if February 23, 1961, to Governor Manuel Barreto of Zambales, you can aplit the income tax payable by you for 1960 (as well as these for subsequent years), paying one-third thereof to the province of Zambales, one-third to the municipality of Itogon, Mountain Province, and the remaining one-third to Baguio City, or in such other proportion which you may consider just and equitable. The necessity for aplitting payment of your income taxes arises because while that corporation maintains an office in Manila and a hiring hall in Baguio City, it conducts its mining operations in Itogon, Mountain Province, and Masinloc, Zambales. Your principal office, however, is in Itogon. In answer thereto, I have the honor to inform you that, under the "pay-as-you-file" system of paying the income tax as provided for in Republic Act No. 2343, when the tax due is P500.00 or less, the same shall be paid in full at the place where the income tax return was filed. On the other hand, when the tax due is in excess of P500.00 and the taxpayer does not elect to pay the same in installments, the first installment shall be paid at the place where the return was filed, while the second installment may be paid at the place desired by the taxpayer. In other words, the income tax is permitted to be paid in installments only when the amount thereof is in excess of P500.00, in which case the law allows the taxpayer to pay the same in two equal installments (Sec. 51(a)(1) A (2), Tax Code as amended by R.A 2343). In view thereof, your query is answered in the negative. aisadc Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue