Tax Imposed on Fees of the Players Who are Non-Resident Aliens Not Engaged in Trade or Business in the Philippines

October 4, 1988 BIR RULING NO. 472-88 29 (h) 338-88 472-88 Gentlemen : In reply to your letter dated September 6, 1988, I have the honor to inform you that the proceeds derived by you from the two exhibition games of the Harlem Ambassadors (formerly Harlem Globetrotters) at the Araneta Coliseum on August 7, and 8, 1988 as part of your nationwide membership and fund campaign for a period of one year pursuant to Proclamation No. 307, which was formerly intended for the Philippine Olympic Committee as part of their fund raising activities in connection with their preparation for the Olympic Games in Seoul, Korea in September and the Southeast Asian Games next year, are not subject to income and business taxes. However, the fees of the players who are non-resident aliens not engaged in trade or business in the Philippines (their stay in the Philippines is for 180 days or less), shall be subject to a tax of 30% on the total amount thereof, pursuant to Section 22(b) of the Tax Code, as amended. cdtech Very truly yours, (SGD.) EUFRACIO D. SANTOS Deputy Commissioner