BIR Ruling No. 121-84

July 19, 1984 BIR RULING NO. 121-84 208-58-80-121-84 Gentlemen : This refers to your letter dated July 2, 1984 requesting a ruling as to the rates of percentage tax on the various income being derived by your client, House of Travel, Inc., 120 Century Plaza, Perea St., Legaspi Village, Makati, Metro Manila. In reply, I have the honor to inform you that for selling tickets in behalf of airlines, your client is considered a commercial broker as defined in Section 187(t) of the Tax Code. Hence, the income derived from commission on ticket sales as well as the incentive income from airlines' sales promotion scheme constitute its gross compensation which is subject to the percentage tax at the rate of 6%, pursuant to Section 208 of the Tax Code. Your client, for organizing local tours, is an independent contractor; hence the gross receipts derived therefrom are subject to the percentage tax at the rate of 3%, pursuant to Section 205(16) of the Tax Code. Finally, for rendering service to clients for documentation of passports, visas, etc., your client is a business agent as defined in Section 187(v) of the Tax Code, hence the gross receipts derived by your client for said services are subject to the percentage tax at the rate of 3%, pursuant to Section 205(16) of the same Code. aisadc Very truly yours, (SGD.)RUBEN B. ANCHETA Acting Commissioner