BIR Ruling No. 057-80

December 4, 1980 BIR RULING NO. 057-80 030-a-1 055-80 57-80 International Spiritual Center and Resorts, Inc. Lucnab, Baguio City Attention : Mr . Alfredo C . Vargas, Jr . Executive Vice-President Gentlemen : In reply to your letter dated October 10, 1980, I have the honor to inform you that under Section 9(a) of Presidential Decree No. 535 in conjunction with Section 6(a) of Republic Act No. 5186, an investor is a registered tourism enterprise which is allowed an investment allowance to be deducted from his taxable income to the extent of his actual investment, paid in cash or property, but not to exceed ten percent thereof, as long as: (1) the investment is made in a subscription of shares in the original and/or increased capital stock of a pioneer enterprise within seven (7) years from the date of registration; (2) that the shares are held for a period of not less than three years; and that the investment is registered with the Board of Investments. The investor must not dispose of the shares within the said three-year period, otherwise he shall lose the benefit of the deduction, his income tax liability shall be recomputed, and he shall pay whatever additional sum be due plus interest thereon, within thirty days from the date of disposition. Furthermore, although the stocks are to be held for a period of not less than three years the investment allowance shall be claimed as deduction only for the taxable year when the investment was made. Very truly yours, RUBEN B. ANCHETA Acting Commissioner