Clarification on the Implementation of Revenue Regulations No. 5-2012

May 7, 2012 REVENUE MEMORANDUM CIRCULAR NO. 022-12 SUBJECT : Clarification on the Implementation of Revenue Regulations No. 5-2012 TO : All Revenue Officials, Employees and Others Concerned This Circular is issued to clarify the implementation and proper interpretation of Revenue Regulations No. 5-2012, to wit: HTcADC 1. All BIR Rulings issued prior to Jan. 1, 1998 are not to be used as precedent by any taxpayer as a basis to secure rulings for themselves for current business transaction/s or in support of their position against any assessment. 2. All BIR Rulings issued prior to Jan. 1, 1998 are not to be used by any BIR action lawyer in issuing new rulings for request for rulings involving current business transaction/s. 3. However, BIR Rulings issued prior to Jan. 1, 1998 remains to be valid but only : a. to the taxpayer who was issued the ruling; and b. covering the specific transaction/s which is the subject of the same ruling 4. BIR Rulings issued prior to Jan. 1, 1998, shall remain valid as mentioned above, unless expressly notified of its revocation or unless the legal basis in law for such issuance has already been repealed/amended in the current Tax Code. All concerned revenue officials and employees are hereby enjoined to give this Circular as wide a publicity as possible. (SGD.) KIM S. JACINTO-HENARES Commissioner of Internal Revenue