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Tax Liabilities of Philippine Seafarers Training Center

BIR Ruling No. 114-86 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jul 17, 1986

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July 17, 1986 BIR RULING NO. 114-86 24 (a) 72-84 114-86 Gentlemen : This refers to your letter dated April 18, 1986 requesting information as to what kind of taxes you are liable to pay. It is represented that Philippine Seafarers Training Center is an educational institution duly accredited by the Ministry of Education, Culture and Sports (MECS); and that it is authorized to conduct special vocational courses from June 17, 1985 to June 16, 1986 under MECS Permit for Special Vocational Courses Nos. V-032, Series of 1983 and V-019-R-2, Series of 1985. In reply, please be informed that pursuant to Section 24(a) of the Tax Code, as amended, as a private educational institution, you are subject to income tax at the preferential rate of ten (10%) per cent of your taxable net income from the operation of your school, related school activities, and on your passive investment income consisting of interest, dividends, royalties, and the like. However, dividends received by you from domestic corporations, shall be subject to the final intercorporate tax of 10% pursuant to Section 24(c) of the Tax Code. Moreover, in view of the amendment of Section 24(cc) (now Sec. 24(d)) in relation to Section 53(d)(1) (now Sec. 51(d)(1) of the Tax Code by P.D. No. 1959 which took effect on October 13, 1984, your interest and/or yield on deposit substitute instruments, and interest income on deposits paid or accrued beginning October 15, 1984 up to December 31, 1985 shall be subject to the final withholding tax of 15%; and to 17-1/2% final withholding tax beginning January 1, 1986 pursuant to Section 24(d) as amended by P.D. No. 1994. cdta Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner

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