July 15, 2010
BIR RULING [DA-(C-028) 122-10]
Section 26; Rev. Regs. 2-98, as amended;
BIR Ruling No. 439-88; DA-490-06; DA-(C-058) 197-08
Du-Baladad and Associates
20th Floor, Chatham House
Herrera cor. Valero Streets
1227 Makati City, Philippines
Attention: Atty. Benedicta Du-Baladad
Managing Partner
Gentlemen :
This refers to your letter dated November 12, 2009 requesting confirmation of your opinion that income payments made to DU-BALADAD AND ASSOCIATES, doing business under the name and style of BDB Law, in consideration for professional services including proceeds from disposition of its properties no longer used in business, are not subject to income tax and consequently, to creditable withholding taxes.
It is represented that DU-BALADAD AND ASSOCIATES (BDB Law) is a general professional partnership duly formed, organized and existing under and by virtue of the laws of the Philippines, with Taxpayers Identification Number 241-924-734-001 and registered with the Securities and Exchange Commission (SEC) as a partnership with SEC Registration No. PP200517675. Its principal place of business is located at the 19th Floor, Tower 1, The Enterprise Center, 6766 Ayala Avenue, Makati City.
It is further represented that BDB Law...