Exemption from Withholding Tax — Lawyers

December 12, 1979 BIR RULING NO. 122-79 In reply to your letter dated January 23, 1979, I have the honor to inform you that the withholding tax provisions of Revenue Regulations No. 13-78, as amended by Revenue Regulations No. 6-79 implementing Presidential Decree No. 1351, particularly Sections 1(a)(1) and (b) thereof apply only to professionals who are individually engaged in the practice of professions and to taxable juridical persons. Since the retainer fees are being paid by your client not to lawyers who are individually engaged in the practice of their profession but to a law office which is a duly registered professional partnership and considering further that said partnership is a non-taxable juridical entity, the retainer fees paid to such partnership are not subject to the withholding tax prescribed by said regulation (See BIR Ruling No. 055-79 dated July 5, 1979).