Occupation Tax Imposed on the Doctors and Nurses of the Silay-Saravia Medical Center

November 9, 1960 BIR RULING NO. 490-60 Hawaiian-Philippine Co. The H. Davis & Co. P.O. Box 287, Manila Gentlemen : Reference is made to your letter dated January 16, 1959 and its inclosure, requesting in effect reconsideration of the ruling issued by the Regional Director, Regional District No. 8, Iloilo City, subjecting to the occupation tax prescribed in section 182(B) of the National Internal Revenue Code the doctors and nurses employed in the Silay-Saravia Medical Center. In answer thereto, I have the honor to inform you that upon investigation conducted by this Office, it has been found that while the aforenamed establishment is a hospital not conducted for private gain, it is however operated jointly by the Hawaiian-Philippine Co. and the Associacion de Hacenderos de Silay-Saravia, Inc. for the exclusive benefit of their respective officials and employees and immediate members of their families. Such being the case, the physicians and nurses, as well as the dentists and pharmacist, employed therein are subject to the occupation tax, even though some or all of them are devoting their entire professional services to said hospital. It is, therefore, regretted that your request has to be, as it is hereby denied. A copy of this ruling has, on even date, been furnished the Regional Director, Iloilo City, for his information. casia Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue