BIR Ruling No. 146-84

September 3, 1984 BIR RULING NO. 146-84 205-00-032-84-146-84 Gentlemen : This refers to your letter dated January 17, 1984 requesting in behalf of your client, DMJM Far East, Inc. for a ruling as to whether its gross receipts from various contracts with the Department of Air Force and the Department of the Navy of the US Government for Architect-Engineer Services to be rendered at the Clark Air Base, Philippines, are exempt from the payment of the 3% contractor's tax. It is represented that your client, DMJM Far East, Inc. is a domestic corporation registered with the Securities and Exchange Commission on August 11, 1982 primarily to engage in the business of project development planners and/or contractors for commercial and industrial projects such as, but not limited to electric power systems, sugar centrals, mines, water resources development projects, wharves and ports, fuel fineries and depots, communicator systems, airfields and airports, roads, highways and bridges, railway lines, factories, commercial and industrial buildings and housing projects; and that under its contracts with the Base Authorities, your client will render architectural and engineering services inside the U.S. Military Base. In reply, I have the honor to inform you that for rendering architectural and engineering services inside the U.S. Military Base by virtue of its contract with Base Authorities your client is exempt from the payment of the 3% contractor's tax in accordance with Article XVIII of the PI-U.S. Military Bases Agreement. However, its income to be derived from the said contracts is subject to corporate income tax under Section 24(a) of the Tax Code. adc Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner