Professional Fees of Experts in the US, Who Render Report Without Actually Coming to the Philippines

July 15, 1960 BIR RULING NO. 332-60 American-Asiatic Oil Corporation Magsaysay Building, San Luis St., Ermita, Manila Attention : Mr . Fernando E . Sison Executive Vice President Gentlemen : Reference is made to your letter dated June 16, 1960, inquiring as to whether the professional fees of experts in the United States, who render report without actually coming to the Philippines are subject to tax. In reply thereto, I have the honor to inform you that in determining whether earned income is from sources within or without the Philippines, the place where the services are performed, and not where the compensation is paid, controls. (Salmon, 3 BTA 838, Dec. 1253) As the Geophoto Services, Inc., a foreign corporation not engaged in trade or business within the Philippines, performed the photogeologic evaluation services outside the Philippines, the professional fees received by it from the American-Asiatic Oil Corporation is not subject to Philippine income tax. Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue