BIR Ruling No. 096-82

March 30, 1982 BIR RULING NO. 096-82 53-f 000-00 096-82 National Electrification Administration Quezon City Attention: Mr . Tany Yu Asensi Corporate Auditor Gentlemen : This refers to your letter dated August 21, 1980, requesting an opinion on whether the gross payments under the contract entered into between DCCD Engineering Corporation and Cebu II Electric Cooperative (CEBECO) are subject to the expanded withholding tax. You have represented that DCCD Engineering Corporation is being engaged by CEBECO for architectural and engineering services. The contract provides for pre-construction services which consists of mapping, preliminary studies, detailed plans and specifications, estimates, drawings, and also the supervision and inspection of the construction of the project. In reply, I have the honor to inform you that said payments are professional fees paid for the practice of professions of architecture and engineering. Accordingly, and since the payments are made to a taxable juridical person, the same are subject to the 5% withholding tax, in accordance with Section 1(b) of Revenue Regulations No. 15-78 as amended by Revenue Regulations No. 6-79. cdtech Very truly yours, RUBEN B. ANCHETA Acting Commissioner