Tax Holidays to Industrial Estates

March 8, 1993 BIR RULING NO. 085-93 TAX HOLIDAYS TO INDUSTRIAL ESTATES 226 206-91 085-93 Philippine Industrial Estate Association 11th Floor, Solidbank Building 777 Paseo de Roxas, Makati, Metro Manila Attention: Mr . Guillermo D . Luchangco President This refers to your request for reconsideration of BIR Ruling No. 048-93 dated January 22, 1993 subjecting industrial estates to income tax, inspite of tax holidays granted by the BOI under the Omnibus Investment Law (EO 226). We have carefully re-studied our position in the context of the macro rationale of said Investment Law and the new salient conditions being imposed by the BOI for the enjoyment of the tax holidays, to wit: a) that industrial estates must register with the BOI for only three (3) more years; b) that such estates must be registered under pioneer status or must be located in less developed areas; and c) that the industrial estates will be set up only in areas that need them with the eventual removal of these estates in the listing (of the IPP) once it is seen that sufficient infrastructure of this nature is already in place. On the basis of the above premises and conditions, this Office interposes no objection to the grant of tax holidays by the BOI under the provisions of EO 226; and, Ruling No. 048-93 is hereby revoked and considered without any force and effect. aisadc JOSE U. ONG Commissioner of Internal Revenue