BIR Ruling No. 340-2020

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

BIR Ruling,No.539g12 o Sec.2(r) of Revenue Bulletin No. 01-2003 01-0340-

San Mateo, Rizal St. Andrew Street, Ampid 1 IC-Richtoneville Subdivision ATTY.RODVICK J.ABARCA IUN 1 9 2020

Sir:

Citinickel Mines and Development Corporation, for clarification and reconsideration relative to your client's.deficiency tax assessment covering taxable year 2013. This refers to your letter filed on April 20, 2018 requesting on behalf of your client.

above matter considering that the issue is still subject of an on-going audit/administrative protest, which is considered as a "No-Ruling Area" pursuant to Section 2 (r) of Revenue Bulletin 01-03. In reply, please be informed that this Office cannot issue a determinative ruling on the

Section 2 (r) of Revenue Bulletin 01-03 provides:

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

or transaction subject of the request is not under investigation, on-going audit, administrative protest, claim for refund or issuance of a tax credit certificate, which is/are the subject of an investigation, on-going audit, administrative protest. claim for refund or issuance of tax credit certificate, collection proceedings, or a judicial appeal subject to Section 3 hereunder. Accordingly, the taxpayer must submit and include the following statement in the request for ruling: "The issue/s collection proceedings, or a judicial appeal of the taxpayer/s involved." r Issue/s or transactions involving directly or indirectly the same taxpayer/s

(Underscoring ours) (BIR Ruling No. 579-12 dated September 19,2012)

Please be guided accordingly.

K-1 Commissioner of Internal Revenue aeeaman CAESAR R.DULAY Very truly yours, 034287

gps (citinickel)