BIR Ruling No. 002-64

January 27, 1964 BIR RULING NO. 002-64 The Manager Llanes & Company 513 P. Gomez, Quiapo Manila S i r : This has reference to your letter dated June 17, 1963, requesting information as to who has jurisdiction regarding the inspection of books of accounts and other records of the Company based on the following facts: "1) That Llanes & Co. has her Head Office of 513 P. Gomez, Quiapo, Manila and factory at Quezon City. "2) That due to the fact that Llaes & Co. has her Head Office of Manila and her desire to consolidate the filing of their income tax return and business tax, she filed at BIR's Office at Canonigo, Manila." In reply thereto, I have the honor to inform you as follows: As a rule, the regional office within whose territory the taxpayer is residing and where his principal place of business is located and where he files his returns and pays his taxes has jurisdiction to examine the taxpayer's returns and books of accounts and other records. Accordingly, under your representation, the Manila regional office has primary jurisdiction, for tax purposes, over your business operations. cdpr However, the Quezon City regional office is not totally deprived of jurisdiction to look into the records of your factory in Quezon City, if the examination of the records therein is necessary in the determination of your tax liabilities, as the Manila regional office can exercise its jurisdiction only within the limits of its territory. For the purpose, therefore, of securing any and all information relative to the operations of your factory in Quezon City, the regional office thereat will naturally have to be utilized to undertake the work of examination and investigation. In resume it may be stated that every regional office of the Bureau of Internal Revenue has jurisdiction to look into the business operations of taxpayers within their respective territories. prcd Very truly yours, (SGD.) BENJAMIN N. TABIOS Acting Commissioner of Internal Revenue