Tax Liability of a Business Agent

August 11, 1960 BIR RULING NO. 343-60 Mrs. Angeles Velasco-Deslate Rm 306 alliance Building Rosario St., Manila M a d a m : In your letter dated July 27, 1960, you stated the following: "I have a client-Corporation duly organized under the laws of the Philippines who intends to buy television time from existing television stations in the country. This television time thus bought will be resold to entities or persons who may want to sponsor the programs or shows presented. "Television films to be purchased or rented by the Corporation from foreign sources will be projected on television by the TV stations' technicians. In the foreseen future, live shows may be presented, the preparation of the programs and the stage artists for which the said Corporation will be responsible. "Sponsors to these films and programs may be solicited by direct contact, by advertisement on television, on periodicals and newspapers, by posted cards and letters. These sponsors will be presented on television within the time purchased by them, by messages and pictures which will be prepared and designed purely by their own advertising departments and units. Rates of sponsorship will be determined by the agreed length of sponsored time." In answer thereto, I have the honor to inform you that your client-Corporation is considered a business agent subject to the fixed and percentage taxes under sections 182 and 191 of the National Internal Revenue Code. Your said client-Corporation is likewise subject to the income and additional residence taxes. Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue