BIR Ruling No. 097-61

March 27, 1961 BIR RULING NO. 097-61 1st Indorsement Returned to the Regional Director, District No. 3, Manila, the papers bearing on the deficiency income tax liability of the London Assurance for 1955. It is the position of this Office that resident-foreign insurance companies are entitled to deduct for income tax purposes an amount equal to 5% of net premiums received in the Philippines as share in head office administration expenses. This Office has construed the term "net premium" as gross premiums less all other deductions chargeable against the insurance business, including returned premiums, reinsurance premiums and the reserve funds mentioned in Section 32 of the Tax Code. prcd This ruling answers also the query of the Chief, Manila Examiners, dated January 26, 1961. He is advised to be guided accordingly. (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue