BIR Ruling No. 534-2020

BUREAU OQINTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Sec. 2(t) of Revenue Bulletin BIR Ruling No. 1089-18 BIR Ruling No.476-14 No. 01-2003; RMO 9-2014 BIR Ruling No.007-15 BIR Ruling No. 556-18 0-0534-2020 SEP 2`3 2020

MR. TOMAS R.PASTOR

Taguig City Bayani Road, Fort Bonifacio Block 60,Lot 3,AFPOVAI

Sir:

condominium building consisting of all the units therein is classified as capital assets. This refers to your letter dated February 12, 2020 requesting for a ruling that your

Bulletin 01-03, as amended. above matter considering that no specific or particular completed transaction was mentioned in your request, which is considered as a "No-Ruling Area" pursuant to Section 2 (t) of Revenue In reply, please be informed that this Office cannot issue a determinative ruling on the

Section 2 (t) of Revenue Bulletin 01-03, as amended, provides:

"SEC. 2. List of No-Ruling Areas. construed and identified as "No-Ruling Areas": -- The following shall hereby be

t)Request for rulings on issue/s or transactions based on hypothetical situations:

Legislative Division. Section 4 thereof provides that the letter request for ruling must be sworn taxpayer or related taxpayer; 3) The issue/s subject of the request is not pending investigation, on- going audit, administrative protest, claim for refund or issuance of tax credit certificate, collection proceeding or judicial appeal; and 4) The documents are complete and that no other documents No. 9-2014 to serve as guideline in the processing of request for rulings filed with the Law and and executed under.oath, must contain a list of submitted documents and must contain the following affirmations: 1) A similar inquiry has not been filed and is not pending in another office of the Bureau; 2) There is no pending case in litigation involving the same issue/s and the same will be submitted in connection with the request. Likewise, on February 6, 2014, this Office issued Revenue Memorandum Order (RMO)

letter request and material to the transaction for ruling must be certified as true copy of the original document by the public officer or private person having custody of the original document. Moreover, Section 5 of the same RMO provides that the documents accompanying the

and that the same letter request was not sworn to and executed under oath, does not contain a list of submitted documents, does not contain the affirmations required under Section 4 of RMO No. In view of the fact that no specific completed transaction was mentioned in your request

OT=0534-2020 SEP 2 3 2020

9-2014, and the accompanying documents submitted with the letter request was not certified as true copy of the original document by the public officer or private person having custody of the original document, your letter request cannot be given due course pursuant to Revenue Bulletin No. 1-2003 and RMO 9-2014. (BIR Ruling Nos. 007-15 dated January 20, 2015; 1089-18 dated July 16, 2018; 007-15 dated January 20, 2015 and 1089-18 dated July 16, 2018)

letter-request coniorms with the said RMO. Be that as it may, we would be glad to process your request for a ruling when the said

Very truly yours,

eamwea

CAESAR R.DULAY Commissioner of Internal Revenue

036474

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K-1 gps (tomas pastor)