Tax Exemption of a General Professional Partnership Formed for the Purpose of Practicing Law

October 22, 1992 BIR RULING NO. 294-92 50 (b) 178-92 294-92 Mr. Elmer P. Lee Villa Lourdes Compound, Ledesma Court Visayas Avenue, Quezon City S i r : In reply to your letter dated May 15, 1992 please be informed that the Gancayco Law Offices which is a general professional partnership formed for the purpose of practicing law is exempt from income tax pursuant to Section 24(a) of the Tax Code, as amended. Accordingly, payments to said partnership for professional services rendered are exempt from the withholding tax provisions of Revenue Regulations No. 6-85 otherwise known as the Revised and Consolidated Expanded Withholding Tax Regulations implementing Section 50(b) of the Tax Code, as amended. However, payments made to individual partners are subject to the 15% withholding tax pursuant to the same Regulations, as amended by Revenue Regulations No. 12-89. Very truly yours, JOSE U. ONG Commissioner of Internal Revenue