BIR Ruling No. 110-62
BIR Ruling No. 110-62 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Oct 5, 1962
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October 5, 1962 BIR RULING NO. 110-62 The Acting Regional Director BIR Regional District No. 3 M a n i l a There is returned to you the docket bearing on the internal revenue case of the Investment Planning Corporation of the Philippines, Ayala Bldg., Manila. It appears that the taxpayer is a corporation engaged in investment business. Its activities consist in soliciting investors and buying for them Filipinas Mutual Fund shares, and in taking custody of the investors' shares. For those services, it charges the investors the so-called sponsor's and custodian fees. Under the above-mentioned circumstances, the corporation is a stockbroker subject to the stockbroker's fixed and percentage taxes prescribed in sections 182(a)(3)(s) and 195 of the Tax Code, because it in effect negotiates the purchase of said shares. cdtech Very truly yours, JOSE B. LINGAD Acting Commissioner of Internal Revenue
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