BIR Ruling No. 336-2018

E REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City LP

Bureau of Internal Revenue Ruling

Republic Act (RA) No. No. 2-98. as amended 9520: Section 2.57.5 (B). Revenue Regulations (RR) Date: March ? 2018 H 336-2018 Person to Contact: Chief. Law Division Tel. Nos. 926-55-36 / 927-09-63

Quezon City PARAMOUNT HUMAN RESOURCE Brgy. Nayong Kanluran, MULTI-PURPOSE COOPERATIVE Unit 1303. The One Executive Bldg.

Attention: RODILYN T. BOTENES Chairman of the Board

Gentlemen:

known as the "Philippine Cooperative Code of 2008. them is subject to two percent (2%) creditable withholding tax, despite the fact that PHRMC is exempted from payment of income tax pursuant to Republic Act (RA) No. 9520, otherwise the income payments made to. Paramount Human Resource Multi-Purpose Cooperative ("PHRMC" This refers to your letter dated January 16. 2017. seeking clarification whether or not " for"brevity) by its clients, in consideration of the manpower services rendered to

through a Contract of Service: and that it was granted Certificate of Tax Exemption No. coop members are deployed to different client companies to render specific manpower services primary objectives are independent job contracting, savings and lending, and other business activities duly authorized by the CDA; that it recruits cooperative members who are skilled workers pursuant to the CDA issued guidelines and ithe provisions of its By-laws and such Authority (CDA) under Registration Number It is represented that PHRMC, with Taxpayers Identification Number (TIN) is a multi-purpose cooperative registered with the Cooperative Development dated September 7. 2016 pursuant to Section 60 of RA No. 9520. dated January 26. 2010: that its

2-98. as amended. implementing Section 57 (B) of the National Internal Revenue Code of i997 as amended, states that: In reply. please be informed that Section 2.57.5 (B) of Revenue Regulations (RR) No.

payments made to the following: withholding tax prescribed in these Regulations shall not apply to income "Sec. 2.57.5. Exemption from Withholding. --- The withholding of creditable

XXX XXX XXX (B) Persons enjoy'ing exemption from payment of income taxes pursuant to the provisions of any lav, general or special, xxx xxx xxx

: 336-2013 PARAMOUNT HUMAN RESOURCE MULTI-PURPOSE COOPERATIVE 3-7-2018

07. 2021 pursuant to the provisions of Section 60 of RA No. 9520, this Office is of the opinion as it hereby holds. that PHRMC is exempt from the payment of creditable withholding tax imposed under RR No. 2-98. as amended. on income payments received from its clients from payment of income taxes for a period of five (5) years from September 07. 20 16 until September September 07. 2016 to September 07. 2021. Accordingly. since PHRMC is a CDA-registered enterprise. enjoying exemption from

if upon investigation. it will be disclosed that the facts are different, then this ruling shall be considered null and void. This ruling is being issued on the basis on the foregoing facts as represented: However.

Very truly yours.

Aea

ZK-1-LMAT Commissioner of Internal Revenue CAESAR R. DULAY 014133

PAGE2 OF 2