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Income Payments to a Partnership of Certified Public Accountants are Not Subject to Withholding Tax

BIR Ruling No. 251-81 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Dec 8, 1981

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December 8, 1981 BIR RULING NO. 251-81 53-F 055-79 251-81 Tahanan Development Corporation Ground Floor, Rufino Building Ayala Avenue, Makati Attention: Mr . Martin G . Sales, Jr . Assistant Manager Gentlemen : In reply to your letter dated February 23, 1981, please be informed that the expanded withholding tax provisions of Revenue Regulations No. 13-78 as amended by Revenue Regulations No. 6-79, implementing Section 53(f) of the Tax Code, as amended by Presidential Decree No. 1351, particularly Section 1(a) and (b) of said regulations, apply only to professionals who are individually engaged in the practice of professions and to taxable juridical persons. Accordingly, since a partnership of certified public accountants is not a taxable juridical person, income payments to it are not subject to the withholding tax prescribed by said regulations. Very truly yours, RUBEN B. ANCHETA Acting Commissioner

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