Gross Receipts Tax on Wholesale Lending Activities
BIR Ruling No. 168-89 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Aug 9, 1989
Full text
August 9, 1989 BIR RULING NO. 168-89 119 000-00 168-89 M a d a m : This refers to your letter dated August 2, 1989, in effect, requesting a ruling as to whether the Development Bank of the Philippines (DBP) is subject to the gross receipts tax on its wholesale lending activities under the Industrial Investment Credit Project (IICP) which has just been negotiated with the World Bank (WB). In reply, please be informed that the bank tax is imposed on the gross receipts derived from all sources within the Philippines by all banks and non-bank financial intermediaries. Even if the DBP is owned or controlled by the government, it is still a bank performing banking activities. Such being the case, the gross receipts which DBP derives from the relending of funds under the IICP Loan to domestic financial institutions are subject to the gross receipts tax prescribed under Section 119 of the Tax Code, as amended by P.D. No. 1739. Very truly yours, (SGD.) JOSE U. ONG Commissioner
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