BIR Ruling No. 141-82

April 23, 1982 BIR RULING NO. 141-82 024-g 000-00 141-82 Bangko Sa Lupa Ng Pilipinas 6th Floor B.F. Condominium Building Intramuros, Manila Attention: Mr . Reynaldo G . Geronimo Trust Officer Gentlemen : This refers to your letter dated September 29, 1980 requesting information on the possible tax obligations of a subsidiary corporation that you plan to organize for the purpose of engaging in the business of acting as investment manager, portfolio manager or fund manager for financial agent of mutual funds, pension funds, foundations, and similar portfolio of persons, natural or juridical, domestic or foreign (but not as trustee of trust fund or properties as provided for in Chapter 7 of Republic Act No. 337, as amended). cd In reply, please be informed that the subsidiary corporation that you are contemplating to form: (1) shall be subject to the corporate tax under Section 24(g) of the Tax Code, of 1977, as amended and under Section 23 of Presidential Decree No. 1177; (2) shall be considered as an independent contractor and therefore subject to the 3% contractor's tax based on gross receipts under Section 205 of the Tax Code; and (3) shall be subject to the annual fixed tax imposed under Section 192(1) of the Tax Code. Very truly yours, RUBEN B. ANCHETA Acting Commissioner