Globe Coco Products Manufacturing Corp.
BIR Ruling [DA-296-08] • Bureau of Internal Revenue (BIR) Issuances • Rulings (Unnumbered) • May 16, 2008
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May 16, 2008 BIR RULING [DA-296-08] E.O. 226; RR 2-98; DA-063-2003; DA-133-2000 Globe Coco Products Manufacturing Corp. Brgy. Lidong, Sto. Domingo, Albay Attention: Ms. Aibe U. Tan Corporate Secretary Gentlemen : This refers to your letter dated January 15, 2008 stating that Globe Coco Products Manufacturing Corp. ("Globe Coco" for brevity), is a corporation duly organized and existing under the laws of the Republic of the Philippines; and that it is registered with the Board of Investments (BOI) for Production of Crude Coconut Oil and Copra Cake as Modernization and Rehabilitation Project under the Omnibus Investments Code of 1987 (E.O. 226) and was given an Income Tax Holiday (ITH) for non-pioneer status for a period of three (3) years starting January 2008. Based on the foregoing, you are requesting exemption from the payment of income tax for the above specified period in accordance with the ITH granted by BOI. In reply, please be informed that based on the specified terms and conditions of Globe Coco's registration with BOI, it has been given an ITH for a period of three (3) years starting January 2008 or until January 2011. As such, Globe Coco is exempt from the payment of income tax for the specified period. Provided, however, that said exemption shall be applicable only to income generated from its registered activities. Moreover, Section 2.57.5 B (2) of Revenue Regulations 2-98, as amended, provides that the withholding tax therein prescribed shall not apply to income payments to persons enjoying exemption from the payment of income taxes pursuant to the provisions of the Omnibus Investments Code of 1987, as amended. As a BOI-registered enterprise, income payments made to Globe Coco from the domestic sale of its products shall not be subject to the creditable withholding tax prescribed in Section 2.57.5 of Revenue Regulations 2-98, as amended. (BIR Ruling No. DA-063-2003 dated March 3, 2003 citing DA-133-2000 dated March 3, 2000) AcSEHT This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. Very truly yours, (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service
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