Tax on Harvesting Cane Contractors Actually Selling Their Services

April 11, 1958 BIR RULING NO. 223-58 Mr. E. A. Narte Accountant, C. J. Yulo & Sons Canlubang, Calamba, Laguna S i r : In reply to your letter dated March 17, 1958, requesting opinion as to whether or not the Harvesting Cane Contractors employed by the Canlubang Sugar Estate every milling season are subject to the 3% contractor's tax imposed by Section 191 of the Tax Code, as amended by Republic Act No. 1612, I have the honor to inform you that Section 191 of the Tax Code, as amended, enumerates the persons and establishments that are subject to the 3% tax imposed on contractors. After the enumeration, the phrase "other independent contractors" follows: This term comprehends all persons not enumerated in said section whose businesses consist essentially of the sale of services. Since the Harvesting Cane Contractors are actually selling their services, they are subject to the 3% tax, the same to be based on their gross monthly receipts. cdtech Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue