Tax Status of a Salesmen

April 22, 1959 BIR RULING NO. 191-59 Mr. A.R. Villar President Ardant Trading Corporation 332 Taylo, Pasay City S i r : Reference is made to your letter dated April 15, 1959, requesting our opinion as to the tax status of your salesmen under the following facts: cdta "This corporation is the exclusive distributor in the Philippines of all the products of the Pan Oriental Match Co., Inc. This corporation has agents throughout the Philippines who sell matches on wholesale basis, for and in behalf of this corporation; they use invoices and receipts of this corporation. The said agents are on salary basis and are given expense allowances. These agents of this corporation do not sell matches for themselves or on commission. They do not have fixed business establishments of their own when they sell the matches for and in behalf of this corporation; when they sell the matches of this corporation, they use panel delivery trucks loaned to this corporation by the manufacturer, the Pan Oriental Match Co., Inc. and travel around their assigned territories." On the basis of the above facts, I have the honor to inform you that your salesmen do not fall within the purview of Revenue Regulations No. V-62. cdt Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue