Revision of BIR Ruling No. 507, Series of 1958

February 18, 1959 BIR RULING NO. 110-59 Messrs. Balcoff, Poblador, & Associates 410 Roman R. Santos Bldg., Plaza Goiti Manila Gentlemen : With reference to your letter dated January 20, 1959, requesting for a revision of BIR Ruling No. 507, Series of 1958, which exempts from tax "only cinematographic films imported by TV Companies for exclusive use in television broadcasts", to the effect that said ruling be made to include "all television films imported into the country for exclusive use by television companies", I regret to inform you that your request cannot be granted. cdt The exemption privileges provided for under Republic Act No. 1919 apply only to TV operators who import cinematographic films for the exclusive use in television broadcasts as can be found in the explanatory note of said Republic Act. In view of the foregoing, and considering that your client is not a TV operator, the exemption privileges granted under Republic Act 1919 cannot be made to extend to it. Accordingly, rentals received by it from the leases of cinematographic films to television companies operating in the country form part of its gross receipts for purposes of the 2% tax prescribed by Section 195 of the Tax Code. Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue