BIR Ruling No. 378-12
BIR Ruling No. 378-12 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jun 6, 2012
Full text
June 6, 2012 BIR RULING NO. 378-12 Regulations No. 011-10; 000-00 Romulo Mabanta Buenaventura Sayoc & De los Angeles 30th Floor, Citibank Tower Makati City Attention : Atty. Priscilla B. Valer Gentlemen : This refers to your letter dated May 27, 2010 stating that your client, Cemex Asia Pte. Ltd.-Philippine Headquarters (Cemex Asia), is licensed to do business in the Philippines as a Regional Operating Headquarters (ROHQ) of Cemex Asia Pte. Ltd. (a foreign corporation organized and existing under the laws of Singapore) pursuant to Book III of Executive Order (EO) No. 226, as amended by Republic Act (RA) No. 8756, as evidenced by Securities and Exchange Commission (SEC) Registration No. FS200906638 issued on May 11, 2009; and that you requested for confirmation of your opinion that the Filipino Executives employed by Cemex Asia are managerial and/or technical employees who have the option to be taxed at 15% gross income pursuant to Section 25 of the Tax Code of 1997, as amended. In reply, please be informed that your queries are sufficiently covered by Revenue Regulations No. 011-10 dated October 26, 2010. The full text of the said regulations is posted in our website www.bir.gov.ph. Please be guided accordingly. SIcCTD Very truly yours, (SGD.) KIM S. JACINTO-HENARES Commissioner of Internal Revenue
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