Occupation Tax Exemption of Professionals in the Philippine Packing Corporation

March 10, 1958 BIR RULING NO. 158-58 Messrs. Meer, Meer & Meer Attorneys-at-Law Suite 302-306 Singson Bldg. Manila Gentlemen : Reference is made to your letter dated March 5, 1958 stating the following: "The Philippine Packing Corporation operates a hospital for the benefit of its employees wherein all medical and hospital facilities are extended to the employees free of charge, Doctors, nurses and other professionals therein render their services exclusively in said hospital and do not charge any fee or compensation for rendering their professional services from all patients therein independent of their salary received from the company." You now seek the opinion of this Office as to whether or not the professionals employed in said hospital are exempt from the occupation tax. In reply thereto, I have the honor to inform you that it appearing as represented that the hospital is not conducted for private gain and that the physicians and nurses and other professionals employed therein devote their entire professional services exclusively thereto, said professionals are exempt from the occupation tax, pursuant to Section 182(c)(7) of the Tax Code. Very truly yours, (SGD.) MELECIO R. DOMINGO Deputy Commissioner of Internal Revenue