Non-deductibility of the Dollar Margin Fee Paid by Branches of Foreign Corporations Doing Business in the Philippines

March 25, 1960 BIR RULING NO. 143-60 Stewart, Cunanan & Co. Certified Public Accountants P.O. Box 2288 M a n i l a Gentlemen : With reference to your letter dated February 18, 1960, requesting reconsideration of the ruling issued by this Office, BIR Ruling No. 35, Series of 1960, I have the honor to inform you that notwithstanding the reasons contained in your said letter, this Office finds no justifiable reason to reverse the same. The opinion of this Office, therefore, holding that the dollar margin fee paid by branches of foreign corporations doing business in the Philippines in remitting profits to their home offices abroad is personal to them in nature and, hence, is not deductible for income tax purposes, still stands. Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue