BIR Ruling No. 208-11
BIR Ruling No. 208-11 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jul 1, 2011
Full text
July 1, 2011 BIR RULING NO. 208-11 IMI International ROHQ North Science Avenue Laguna Technopark SEZ, Bian, Laguna Attention: Mr. Jaime G. Sanchez Deputy CFO and Controller Gentlemen : This refers to your letter dated September 10, 2009 requesting for confirmation of your opinion that the compensation received by the alien executives and Filipino managerial employees of IMI International ROHQ ("IMI-ROHQ") shall be subject to tax at a rate of 15% pursuant to Section 25 (C) of the Tax Code of 1997 and Article 61 of Republic Act (R.A.) No. 8756. Please be informed that Revenue Regulations (RR) No. 11-2010 dated October 26, 2010 further clarifies the term "Managerial and Technical Positions" under RR No. 2-98, as amended and modifies for this purpose RMC No. 41-09 including guidelines on availment of the 15% preferential Income Tax rate for qualified Filipino personnel employed by Regional or Area Headquarters and Regional Operating Headquarters of multinational companies. RR No. 11-2010 introduced a new procedure on the application for preferential rate. For this reason, the issue raised in your letter cannot be acted upon by this office as it is no longer a ruling area. You are advised to comply with the requirements set forth in RR No. 11-2010 should you wish to apply the preferential rate to your qualified employees. cHaDIA Very truly yours, (SGD.) KIM S. JACINTO-HENARES Commissioner of Internal Revenue
Ask what this means for your situation
The assistant quotes the passage it relies on and links the source, so you can check every figure it gives you.