Tax Liability of Century Geophysical Corporation

July 13, 1959 BIR RULING NO. 328-59 Messrs. Sycip, Gorres, Velayo & Co. Certified Public Accountants 490 San Luis, Manila Gentlemen : Reference is made to your letter dated July 9, 1959 stating the following: "Our client, Century Geophysical Corporation, a foreign corporation engaged in business in the Philippines has contracts for geophysical surveys with companies engaged in petroleum explorations in the Philippines. The corporation also acts as technical consultants for other companies for which it receives fees. The corporation employs geophysicists and other technical men in connection with its survey and consulting services. We believe that the survey and consulting fees paid to the corporation are not subject to the 3% tax provided under section 191 of the Tax Code and the geophysicists employed by the corporation are not subject to the occupation tax." You now request information whether or not the Corporation is subject to the 3% tax under section 191 of the Tax Code and whether or not the geophysicists employed by the Corporation are subject to the occupation tax prescribed by section 182 of the same Code. In reply thereto, I have the honor to inform you that the Century Geophysical Corporation, as geophysical surveyors and as technical consultants, is not subject to the 3% percentage tax prescribed by section 191 of the Tax Code; and the geophysicists employed by it are not subject to the occupation tax prescribed by section 182 of the aforesaid Code. cdta Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue