Bank Deposits by Branches Should be Paid with the Revenue District Office Where the Principal Office is Located

July 12, 1987 BIR RULING NO. 199-87 52 000-00 199-87 Gentlemen : This refers to your letter dated May 12, 1987 requesting a ruling as to whether your client, Philippine Commercial International Bank (PCIB) can continue its long standing practice of having its branches remit to its Head Office in Makati the taxes withheld on bank deposits and the Head Office will in turn remit such taxes to the Bureau of Internal Revenue. In reply thereto, I have the honor to inform you that Section 5 of Revenue Regulations No. 17-84 as amended by Revenue Regulations No. 23-84 implementing Section 52 of the Tax Code has been amended by Revenue Regulations No. 3-85 reading as follows: "SEC. 5. Manner of Filing Returns and Payment of Taxes . The taxes herein deducted and withheld shall be declared in a return which shall be filed in duplicate within twenty-five (25) days after the end of each quarter of any calendar year with the Revenue District Officer or Collection Agent or duly authorized Treasurer of the city or municipality where the withholding agent's principal office is located and where its books of accounts are kept except in cases where the Commissioner of Internal Revenue otherwise allows. Upon filing of the return payment of the taxes shall be made to accredited banks, or, in places where there are no such banks, to the Collection Agent or authorized Municipal Treasurer." Such being the case, the taxes deducted and withheld under Section 51(a) in relation to Section 24 (e)(1) of the Tax Code, as amended, on bank deposits by the branches of your client should be paid with the Revenue District Office of Makati where the principal office of your client is located and where its books of accounts are kept. (Section 52, NIRC) Accordingly, the long standing practice of your client of having its branches remit to its Head Office the taxes withheld on bank deposits and the Head Office to remit said taxes to the BIR is legal and proper. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner