Taxability of the Proceeds Derived from the Non-Title Fight of Dodie Boy Peñalosa (Phils.) and Biwon Chung (Korea)

September 1, 1988 BIR RULING NO. 428-88 30-h 338-88 428-88 Gentlemen : In reply to your letter dated August 30, 1988, please be informed that the proceeds to be derived by you from the non-title fight between Dodie Boy Pealosa of the Philippines and Biwon Chung of Korea at the Araneta Coliseum on September 2, 1988 as part of your fund-raising campaign in preparation for the Seoul Olympics this September are not subject to income tax. Moreover, gifts, bequests, donations and/or contributions to you during the period of your national fund campaign from June 1, 1988 to May 30, 1989 shall be exempt from the donor's and estate taxes and shall be deductible in full in computing the taxable net income of the donor provided that not more than thirty per centum of said gifts and bequests shall be used by you for administration purposes pursuant to Proclamation No. 263 in relation to Presidential Decree No. 507. However, the money prizes exceeding P3,000.00 to be derived by the Filipino participant in said boxing promotion shall be subject to a final tax of 20% pursuant to Section 21(c)(1) of the Tax Code, as amended, while money prizes amounting to P3,000.00 or less shall be subjected to tax under Section 21(a) of the same Code. On the other hand, the money prizes of Mr. Biwon Chung shall be subject to a tax of 30% on the total amount thereof under Section 22(b) of the Tax Code. Moreover, as promoter having the receipt, control, custody, disposal and payment of the money prizes, you are liable to withhold the aforesaid 20% and 30% final taxes before paying such money prizes to the persons entitled thereto pursuant to said Section 21(c)(1) and 22(b) in relation to Sections 51 and 53 (renumbered Sections 50 and 52 by Executive Order No. 273), all of the Tax Code, as amended by Executive Order No. 37. aisadc Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner