BIR Ruling No. 195-82
BIR Ruling No. 195-82 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jun 14, 1982
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June 14, 1982 BIR RULING NO. 195-82 53-f 000-00 195-82 Philippine Packing Corporation Kayamanan "C" Village No. 2263 Pasong Tamo Extension Makati, Rizal 3116 Attention: Mr . Danilo A . Soriano Gentlemen : This refers to your letter dated February 5, 1979 requesting a certification that your company is exempt from the withholding tax requirements of Presidential Decree No. 1351 as implemented by Revenue Regulations Nos. 13-78 and 6-79. It is represented that you have an existing sub-agency agreement with the International Harvester Macleod, Inc. whereby as sub-agent for said Company, you are authorized, empowered and directed to act as exclusive sub-agent for the agent in the conduct and management of the business of vessels of States Marine Lines, an American Corporation, at the port of Bugo, Misamis Oriental. In reply, I have the honor to inform you that under the foregoing facts, you are a management agency; hence 15% of the gross payments to you on account of said agency are subject to the 3% withholding tax, pursuant to Section 1(e)(1)(1) of Revenue Regulations No. 13-78, as amended by Revenue Regulations No. 6-79, implementing Section 53(f) of the Tax Code. cdtech Very truly yours, RUBEN B. ANCHETA Acting Commissioner
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