BIR Ruling No. 118-82

April 15, 1982 BIR RULING NO. 118-82 53-f 000-00 118-82 Atty. Hortencio V. Taeza State Investment House, Inc. 223 Juan Luna Street M a n i l a S i r : This refers to your letter dated October 25, 1980, requesting clarification whether payment of consultancy fee to a financial intermediary performing quasi-banking function, for services rendered to its client involving the formulation of financial plans and the packaging of capital requirements, is subject to expanded withholding tax. In reply, I have the honor to inform you that, under the foregoing facts, the financial intermediary is considered a management and technical consultant. Hence, the income payments to it on account of said services, are subject to the 5% withholding tax in accordance with Section 1(b) of Revenue Regulations No. 13-78, as amended by Revenue Regulations No. 6-79. cdta Very truly yours, RUBEN B. ANCHETA Acting Commissioner