BIR Ruling No. 161-14

May 30, 2014 BIR RULING NO. 161-14 Atty. Jude John F. Perez 25th Floor Galleria Corporate Center EDSA corner Ortigas Avenue Quezon City 1110 Sir : This refers to your letter dated 07 February 2014 wherein you requested for guidance with respect to the tax consequences of the transaction between your client, Innovathink Corporation, and Ikon Solutions Ltd. Revenue Memorandum Order (RMO) No. 9-2014 dated February 6, 2014 lays down the guidelines in the processing of requests for rulings with the Law and Legislative Division of the Bureau of Internal Revenue. Section 4 of the said RMO partly reads: "Section 4. Letter Requests for Ruling . A letter request is a sworn statement executed under oath by the individual taxpayer or by the authorized official/representative of the corporation, partnership or entity containing the following: (1) Factual background of the request for ruling, including: a. names, addresses, and taxpayer identification numbers of all interested parties; aATEDS b. a complete statement of the business reasons for the transaction; and c. a detailed description of the transaction or circumstances involved. (2) The issues/questions raised or conclusions sought to be confirmed by the taxpayer; (3) The legal grounds and the relevant authorities supporting the position of the taxpayer; (4) List of documents submitted; and (5) Affirmations stating that: 1. a similar inquiry has not been filed and is not pending in another office of the Bureau; 2. there is no pending case in litigation involving the same issue/s and the same taxpayer or related taxpayer; 3. the issue/s subject of the request is not pending investigation, on-going audit, administrative protest, claim for refund or issuance of tax credit certificate, collection proceeding or judicial appeal; and 4. the documents submitted are complete and that no other documents will be submitted in connection with the request." We regret to inform you that your letter request failed to comply with the foregoing requisites. Thus, we are compelled to deny your request. EaHcDS Very truly yours, (SGD.) KIM S. JACINTO-HENARES Commissioner of Internal Revenue