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Tax Liability of a "Physiotherapy"

BIR Ruling No. 104-60 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Mar 9, 1960

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March 9, 1960 BIR RULING NO. 104-60 Mr. Guillermo I. Ventura 744 Quezon Boulevard Quiapo, Manila S i r : In reply to your letter dated February 16, 1960, I have the honor to inform you, that while "physiotherapy" constitutes a practice of medicine under Section 10 of Republic Act No. 2382 (Medical Act of 1959), yet a "physiotherapist" is not subject to the occupation tax prescribed for medical practitioners unless he is really a physician. However, since "physiotherapy" involves the uses of physical agents such as massage (State V. Bain, Mont., 295 P2d 241, 243), you are therefore, subject as a "physiotherapist" to the occupation tax of fifty (P50.00) pesos prescribed for masseurs in Section 182 (B) (2) of the Tax Code. cdll Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue

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