Payments Made for Health Care Services Actually Rendered by Doctors Not Subject to Expanded Withholding Tax

December 4, 1986 BIR RULING NO. 265-86 051-f 63-81 265-86 S i r : This refers to your letter dated October 20, 1986 requesting a ruling as to whether or not the payments to be made by your clients, including the Philippine Long Distance Telephone Company (PLDT) in your favor are subject to the expanded withholding tax under Revenue Regulations No. 6-85 implementing Section 51(f) of the Tax Code as amended. It is represented that PLDT and the Consolidated Health System, Inc. has entered into a contract, whereby the latter on retainer basis undertook to provide contracted professional services of a team of medical doctors. In reply thereto, I have to honor to inform you that under the aforesaid Regulations, payments only to persons enumerated therein are subject to withholding tax. Accordingly, since payments made by PLDT in your favor for health care services actually rendered by the said doctors are not among those specified in the Regulations, the same are not subject to the expanded withholding tax. aisadc Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner of Internal Revenue