BIR Ruling No. 091-63

December 4, 1963 BIR RULING NO. 091-63 2nd Indorsement Returned, thru the Revenue Operations Head (Assessment), to the Chief, Income Tax Division, Manila, the papers bearing on the queries propounded by the P. Nolasco De Silva & Co., Inc., and informing him as follows: cdta Admittedly so-called sub-agents are by themselves brokers as in fact they are duly provided with the broker's privilege tax receipt and had been paying the percentage tax on the commissions received by them. Under the circumstances, so-called sub-agents cannot be bonafide employees of said firm, and, therefore, the commissions received by them are not subject to the withholding tax. (SGD.) RAMON T. OBEN Acting Commissioner of Internal Revenue This is to certify that the above ruling was signed by the Commissioner of Internal Revenue on December 4, 1963. cdti (SGD.) AMBROSIO LINA Revenue Operations Head (Legal)