Payments for Leasehold Right under a Contract of Lease are Not Subject to Expanded Withholding Tax
BIR Ruling No. 328-87 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Oct 23, 1987
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October 23, 1987 BIR RULING NO. 328-87 51 (b) 000-00 328-87 Gentlemen : In reply to your letter dated October 8, 1987, I have the honor to inform you that under Revenue Regulations No. 13-78, as amended by Revenue Regulations Nos. 6-79 and 6-85, implementing Section 51(b) [formerly Sec. 51(f)] of the Tax Code, payments only to persons enumerated therein are subject to the expanded withholding tax. Considering that payments for leasehold right under a contract of lease are not among those specified in said Regulations, such payments are not, therefore, subject to the expanded withholding tax. However, since the aforesaid payments are not subject to withholding tax, the payor shall render an information return on such payments pursuant to Section 71 (formerly Section 77) of the Tax Code, as amended by Batas Pambansa Blg. 135 and as implemented by Section 21 of Revenue Regulations No. 1-82 dated March 18, 1982. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner
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