BIR Ruling [DA-354-97]

October 30, 1997 BIR RULING [DA-354-97] Esla Land Developers, Inc. and Green Valley Country Club of Baguio Green Valley Townhouse, No. 55 Kaimito St. Valle Verde Subdivision, Pasig City Attention: Ms. Precy P. Sy Gentlemen : This refers to your letters dated March 14, 1997 requesting for clarification as to whether or not BIR Ruling No. 521-93 also applies to the following corporations: BAGUIO ESLA REALTY & DEVELOPMENT CORPORATION ESLA REALTY & DEVELOPMENT CORPORATION ESLA LAND DEVELOPERS, INC. and GREEN VALLEY COUNTRY CLUB OF BAGUIO Records show that four (4) separate letters all dated August 20, 1992 were received by this Office from Esla Land Developers, Inc., Esla Realty & Development Corporation, Baguio Realty & Development Corporation and Green Valley Country Club of Baguio on September 2, 1992; and that the said letters were requesting for an exemption from the payment of the expanded creditable withholding tax imposed under Revenue Regulations No. 1-90 amending Revenue Regulations No. 6-85, implementing Section 50 (b) of the Tax Code, as amended, because the sale of lots referred to therein were allegedly made prior to the effectivity of said Revenue Regulations No. 1-90, hence the latter is not applicable. aDHScI In reply, please be informed that BIR Ruling No. 521-93 dated December 27, 1993 was addressed to Esla Land Developers, Inc. only. The corresponding clarification is hereby made by including Baguio Esla Realty & Development Corporation, Esla Realty & Development Corporation and Green Valley Country Club of Baguio as among those to whom the said BIR Ruling is applicable with equal force and effect. Such being the case, BIR Ruling No. 521-93 dated December 27, 1993, applies not only to Esla Land Developers, Inc. but also to Baguio Esla Realty & Development Corporation, Esla Realty & Development Corporation and Green Valley Country Club of Baguio. Very truly yours, (SGD.) SIXTO S. ESQUIVIAS IV OIC, Asst. Commissioner (Legal Service)