BIR Ruling No. 264-15

July 30, 2015 BIR RULING NO. 264-15 Section 2 (t), Revenue Bulletin No. 1-2003; BIR Ruling No. 082-10 Atty. Alquin B. Manguera 1348 Kundiman Street, Sampaloc, Manila Sir : This refers to your letter dated 5 April 2013, requesting for a ruling based on the proposed contract for interior design of a store here in the Philippines. In connection with the foregoing, you are requesting for a ruling/opinion on the following: 1) Whether or not the services of an interior designer, a foreign corporation not doing business in the Philippines and has no representative office here in the Philippines in a domestic corporation in the Philippines is taxable under Philippine laws. In reply, please be informed that Section 2 (t) of Revenue Bulletin No. 1-2003 which "Prescribes the Procedure and Guidelines for the Proper Handling of Request for Rulings which are Determined as "No-Ruling Areas", and Providing the Initial List of "No-Ruling Areas" dated July 14, 2003, provides, viz. : "Section 2. List of No-Ruling Areas . The following shall hereby be construed and identified as "No-Ruling Areas": xxx xxx xxx t) Request for rulings on issue/s or transactions based on hypothetical situations." In view of your representation that the transaction is still in the " proposal stage " thus neither existing nor partially executed, this Office cannot as yet issue a definitive ruling or opinion on the above matter considering that the issue is based on hypothetical situation, which is considered as a "No-Ruling Area" pursuant to Section 2 (t) of Revenue Bulletin 01-03. (BIR Ruling No. 082-10 dated October 5, 2010) Be that as it may, we would be glad to process your request for a ruling when the transaction is executed and carried out by the concerned parties. Please be guided accordingly. Very truly yours, (SGD.) KIM S. JACINTO-HENARES Commissioner of Internal Revenue