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April 5, 1973 IBM Philippines, Inc. 8757 Paseo de Roxas Makati, Rizal Attention: Mr . J . R . Tapay Manager of Financial Programs Gentlemen : This refers to your letter dated March 28, 1973 requesting information as to whether or not your gross receipts derived from rental of personal property leases to the Asian Development Bank is subject to the 3% contractor's tax, considering that the Asian Development Bank is a tax-exempt entity. In reply, I have the honor to inform you that the fact that the Asian Development Bank is a tax-exempt entity does not relieve you from the duty of paying the 3% tax imposed under Section 191 of the Tax Code on your gross receipts derived from said customer, said tax being directly imposed upon you as contractor. (BIR Quarterly Bulletin, Vol. IV, No. 4). Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue