BIR Ruling No. 301-61
BIR Ruling No. 301-61 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Aug 17, 1961
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August 17, 1961 BIR RULING NO. 301-61 Reference is made to your letter . . . stating the following: cdt "My client, a resident American foreign corporation, will be engaging in architectural and engineering services consisting of designs, specifications, estimating, consultation, engineering surveys, inspection and supervision of constructions, in U.S. military bases in the Philippines. It will also accept jobs from various private entities and individuals." "Questions: What kind of taxes, if any, will the said corporation be liable to pay based on the above-mentioned facts?" In reply thereto, I have the honor to inform you that your client is a contractor, but it is exempt from the 3% contractor's tax on its receipts under contracts with U.S. Military Bases in the Philippines, pursuant to the Military Bases Agreement of 1947, as supplemented by the Agreement of December 29, 1952. It will however be subject to the 3% percentage tax with respect to jobs performed for other persons. Your client is of course subject to the fixed tax. In both cases, the earnings are subject to the income and residence taxes.
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