Exemption from the Corresponding Occupation Taxes Prescribed by the NIRC

September 22, 1960 BIR RULING NO. 457-60 1st Indorsement Returned to the Chief, Narcotic Drugs Unit, thru channels, Manila, the herein papers with the following information: cdtech Filipino professionals, such as physicians, dentists, pharmacists and nurses, who are civilian employees of any hospital, sanitarium, or similar establishment of the United States Armed Forces, United States Navy or other agencies of the United States Government, not conducted for private gain, and devoting their entire professional services as such, are exempt from the corresponding occupation taxes prescribed by the National Internal Revenue Code. This ruling is based on the pertinent portion of Section 182(C)(7) which says "(7) . . ., or persons devoting their entire professional services to any religious, educational, or charitable institution, or hospital, sanitarium, or to any similar establishment, not conducted for private gain in respect to the tax imposed by paragraph (B) of this section." While it is true that the first portion of the same provision of law limits the exemption to persons employed in the service of the Government of the Philippines, yet, the last portion of said provision, above-quoted, equally extends the exemption privilege to those persons devoting their entire professional services to any hospital, sanitarium, charitable institutions, among others, regardless of whether said hospital, etc., are managed or supervised or financed by the Philippine Government or any government for that matter. aisadc Please be guided accordingly. MELECIO R. DOMINGO Commissioner of Internal Revenue