Taxability of Business Agents

September 2, 1959 BIR RULING NO. 453-59 The Fidelity Sales & Services, Inc. 2151 Taft Avenue, Manila Gentlemen : This is with reference to your letter dated September 4, 1958, requesting information as to the taxability of your business. You furnished us the following information as regards the nature thereof, to wit: " Nature of business to solicit members, who will be charged for a yearly nominal fee, thereafter, will be entitled to privileges and benefits as follows: "1. Special discounts from leading household and electrical appliances stores; department stores; clinics; hospitals; druggists and other business establishments. "2. To facilitate & expedite contacts for the members, who needs the services or advices, at the most reasonable fees or charges of the following: a. Household & electrical appliances repair. b. Services of 'business, financial & tax consultants', certified public accountants, lawyers, architects, engineers, surveyors, 'private nurses, midwives, tutors, and detectives'. c. Family counsellors, particularly with children's cases (by U.S. trained psychiatrists and psychologists) d. Tickets for fights, concerts, games & movies. e. Cargo trucks, service car, urgent delivery or pick-ups. f. And etc." In answer thereto, I have the honor to inform you that under the foregoing circumstances, you are considered business agents (agente de negocios), and, as such, you are liable for the payment of the business agent's fixed and percentage taxes under sections 182(A-3-W) and 191 of the Tax Code and the income and additional residence taxes. cdta Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue