BIR Ruling No. 109-61

April 25, 1961 BIR RULING NO. 109-61 Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accountant P. O. Box 589, Manila Gentlemen : Reference is made to your letter of the 21st instant, requesting confirmation of your opinion that the proceeds to be derived from the sale to be made by the Chronicle Broadcasting Network of its radio and television airtime covering the period of one (1) year to the Bolinao Electronics Corporation, as well as the gross receipts that the latter may derive from the resale to sponsors and advertisers of said airtime, are not subject to any privilege, percentage and franchise taxes. In answer thereto, I have the honor to inform you that, based on your representations that the Chronicle Broadcasting Network and the Bolinao Electronics Corporation are owners and operators of radio broadcasting and television stations, this Office shares the view that they are respectively exempt from those taxes on the sale and resale of the airtime in question, pursuant to Republic Act No. 2889, as implemented by General Circular No. V-324. LLphil Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue