BIR Ruling No. 156-61

May 12, 1961 BIR RULING NO. 156-61 Messrs. Ponce Enrile, Siguion Reyna, Montecillo & Belle Seventh Floor, Soriano Building Manila Gentlemen : With reference to your letter dated May 8, 1961, I have the honor to inform you that the ruling contained in our letter dated September 17, 1957 to your client, Goodyear Tire and Rubber Company of the Philippines, Ltd., has not been revoked. llcd Accordingly, the efficacy of said ruling shall continue as long as the "Service Agreement" entered into between your client, Goodyear Tire and Rubber Company of the Philippines, Ltd., and Goodyear Tire and Rubber Co. of Akron, Ohio, U.S.A. remains in force. It may be stated in this connection that, as a rule, in the determination of the question of source of income in connection to services rendered, the criterion is the place where the services are rendered and not where payment for the services is made. Hence in the ruling in question, we held that remittances made by Goodyear (Phil) to Goodyear (U.S.A.) on account of services rendered by the latter in the U.S. are not subject to the withholding provisions of Section 54 of the Tax Code. LibLex Very truly yours, (SGD.) MISAEL P. VERA Deputy Commissioner of Internal Revenue