BIR Ruling No. 163-61
BIR Ruling No. 163-61 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • May 8, 1961
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May 8, 1961 BIR RULING NO. 163-61 The Secretary Durisol Philippines, Inc. R-406 Trade and Commerce 215 Juan Luna, Manila S i r : In answer to the query posed in your letter of the 3rd instant, I have the honor to inform you as follows: cdll Nonresident alien individuals and foreign corporations are subject to Philippine income tax only on income derived by them from sources within the Philippines. On the other hand, compensation for labor or personal services performed in this country are considered income from sources within the Philippines and those for labor or personal services performed outside thereof income from sources without the Philippines (Sec. 37(a-(3) and (c)(3), Tax Code). Such being the case, and based on your representations that the consulting fee mentioned in said letter is due to foreign technicians for services rendered by them abroad to the corporation, such fee is not subject to Philippine income tax. Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue
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