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Freight Receipts Derived from Incoming Cargoes Not Subject to the 1% Expanded Withholding Tax

BIR Ruling No. 108-86 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jul 11, 1986

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July 11, 1986 BIR RULING NO. 108-86 51-f 000-77 108-86 Gentlemen : This refers to your letter dated November 11, 1985, requesting clarification if your freight receipts derived from incoming cargoes are subject to the withholding tax of 1% inasmuch as said receipts are not subject to the 3% common carrier's tax under Section 173 of the Tax Code. In reply thereto, I have the honor to inform you that this Office has ruled that our withholding tax law is not applicable and effective abroad. Such being the case, freight receipts derived by you from incoming cargoes are not subject to the expanded withholding tax of 1% pursuant to Section 1(e)(2)(e) of Revenue Regulations No. 6-85 as amended by Revenue Regulations No. 6-85 implementing Section 51(f) of the Tax Code, as amended. cdti Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner

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