BIR Ruling No. 217-82
BIR Ruling No. 217-82 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jul 26, 1982
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July 26, 1982 BIR RULING NO. 217-82 053 (f) 69-81 217-82 Sycip, Gorres, Velayo & Co. Philamlife Building Jones Avenue, Cebu City Gentlemen : In reply to your letter dated April 16, 1982, please be informed that being a registered partnership of licensed professional architects, your client, Caizares, Dizon, Mapeso and Fernandez Co., of 516 Mango Avenue, Cebu City, is exempt from income tax pursuant to Section 24(a) of the Tax Code, as amended. Accordingly, payments to the said partnership for professional services rendered are exempt from the withholding tax provisions of Revenue Regulations No. 13-78 as amended by Revenue Regulations No. 6-79, both implementing Section 53(f) of the Tax Code as amended by Presidential Decree No. 1351. Likewise, as a professional partnership it is not considered a contractor, hence not subject to the 3% contractor's tax prescribed by Section 205 of the Tax Code, as amended. Very truly yours, RUBEN B. ANCHETA Acting Commissioner
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