Taxability of Fitness International

July 13, 1988 BIR RULING NO. 314-88 26 (e) 000-00 314-88 Gentlemen : This refers to your letter dated November 23, 1987 requesting a ruling on the taxability of your client, Fitness International, to the value-added tax. It is represented that your client is a domestic corporation engaged in physical fitness program and maintain physical fitness equipment and facilities; that your client gives instructions to each member to use the different equipment and facilities to attain physical fitness; that for such services and facilities, your client receives monthly membership fees and a one-time entrance fee. In reply, please be informed that the foregoing activities of your client do not constitute sale of services within the purview of Section 2(j) of Revenue Regulations No. 5-87.Accordingly, it is not subject to the value-added tax imposed by Section 102 of the Tax Code as amended by Executive Order No. 273. However, your client is subject to income tax under Section 24(a) of the Tax Code. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner