Income of a Duly Registered General Co-partnership Engaged in the Operation of the Bambang Clinic and Hospital

October 21, 1958 BIR RULING NO. 646-58 Mr. Marcelo Rafols Javier Attorney-at-Law R-309 Laperal Building 851 Rizal Avenue, Manila S i r : In reply to the queries contained in your letter dated May 14, 1956, I have the honor to inform you as follows: The income of a duly registered general co-partnership engaged in the operation of the Bambang Clinic and Hospital, now Immaculate Concepcion Hospital of Manila, is not subject to the corporate income tax, pursuant to Section 24(A) of the Tax Code. However, the members of the partnership should report in their respective individual income tax returns, their distributive shares of the net income of such partnership, whether distributed or not, in accordance with Section 26 of the said Code. For the operation of the hospital and clinic, the aforesaid partnership is not subject to any internal revenue business tax. If the hospital sells locally purchased medicines to its patients and to the general public, it is subject to the graduated fixed annual tax (C-13) pursuant to Section 182(A)(2) of the National Internal Revenue Code. It is not, however, subject to the graduated fixed annual tax if it sells exclusively to its patients. The aforesaid partnership is subject to the annual basic and additional residence taxes prescribed by Section 2 of Commonwealth Act No. 465, otherwise known as the Residence Tax Law. LLphil Very truly yours, (SGD.) MELECIO R. DOMINGO Acting Commissioner of Internal Revenue