BIR Ruling No. 200-61

April 20, 1961 BIR RULING NO. 200-61 Mr. Gregorio O. Calit Certified Public Accountant P. O. Box No. 33, Oroquieta Misamis Occidental S i r : Reference is made to your letter dated March 18, 1961, requesting information whether or not, under the following facts, "A" is an independent contractor: llcd "Facts : Mr. 'A' is an operator of Corn & Rice Mill. In order to have a continuous supply of corn grain and palay for his mill, he plans to buy a tractor with which he would contract with farmers to plow their farms for an agreed price per hectare with the further condition that the production in excess of the farmer's consumption be sold only to said Mr. 'A'. In answer thereto, I have the honor to inform you that plowing the field of another or others for an agreed price is a sale of services and constitutes the person selling the services an independent contractor within the meaning of Section 191 of the Tax Code. Accordingly, "A" is subject to the fixed and percentage taxes prescribed in Sections 182(A)(1) and 191 of said Code. Needles to state, the tax liability of "A" as an operator of a rice and corn mill is not altered by his being at the same time an independent contractor. LibLex Very truly yours, (SGD.) MISAEL P. VERA Deputy Commissioner of Internal Revenue