BIR Ruling No. 105-62

September 12, 1962 BIR RULING NO. 105-62 The General Manager National Power Corporation P. O. Box 2123, Manila S i r : With reference to your 1st Indorsement dated March 15, 1962, requesting exemption for and in behalf of the nurse, dentist and physician employed therein from the occupation tax, I have the honor to inform you that professionals employed in government-owned or-controlled corporations performing public or governmental functions fall within the purview of "persons employed in any branch of the service of the Government of the Philippines" who are exempt from the occupation tax pursuant to Section 182(c)(7) of the Tax Code, provided that their entire professional services are devoted exclusively thereto or applied under their direction. Accordingly, and as the National Power Corporation is one performing public or governmental functions (Opinion No. 213, s. 1958, citing Opinion No. 230, s. 1941 Secretary of Justice), the nurse, dentist, physician and others employed therein whose entire professional services are devoted exclusively thereto or applied under its direction are exempt from the occupation tax. However, those whose entire professional services are not devoted exclusively to the Corporation or applied under its direction are subject to said tax. B.I.R. Ruling No. 62-0050 is hereby modified accordingly. aisadc Very truly yours, JOSE B. LINGAD Acting Commissioner of Internal Revenue