Section 1.
Classification/
Description of
Revenue Issuances. – Aside from Revenue Regulations, which are issued by the
Secretary of Finance upon recommendation of the
Commissioner of Internal Revenue, under Revenue Administrative
Order No. 1-2003, the revenue rulings and issuances that implement or interpret tax laws are classified and described as follows:
a) Rulings of first impression. - These refer to the rulings, opinions and interpretations of the Commissioner of Internal Revenue with respect to the provisions of the Tax
Code and other tax laws without established precedent, and which are issued in response to the specific request for ruling filed by a taxpayer with the
Bureau of Internal Revenue. Provided, however, that the term shall include reversal, modification or revocation of any existing ruling.
b) Rulings with established precedents. - These refer to mere reiteration of previous rulings, opinions and interpretations of the
Commissioner, which may be delegated by the Commissioner from time to time at his/her sole discretion to duly authorized internal revenue officers (i.e.,
Deputy Commissioner,
Legal and Inspection
Group;
Assistant Commissioner,
Legal Service;
Regional Directors) that are issued in response to a specific request for ruling filed by a taxpayer with the Bureau of Internal Revenue.
c) Revenue
Memorandum Rulings (
RMR). – These refer to the rulings, opinions and interpretations of the Commissioner of the Internal Revenue with the respect to the provisions of the Tax code and other tax laws, as applied to a specific set of facts with or without established precedents, and which the Commissioner may issue from time to time for the purpose of providing taxpayers guidance on the tax consequences in specific situations.
Revenue
Special Orders (
RSO). –
Instructions or directives for the accomplishment of special assignments or missions of significance which are temporary in nature or for a definite period of time. These issuances specifically mention the personnel or units of organization concerned.
g) Revenue Memorandum Circulars (
RMC). – These issuances shall disseminate and embody pertinent and applicable portions, as well as amplifications of the rules, precedents, laws, regulations, opinions and other orders and directives issued by or administered by the Commissioner of Internal Revenue, and by offices and agencies other than the Bureau of Internal Revenue, for the information, guidance or compliance of revenue personnel.
h) Revenue Memorandum Orders (
RMO). – These are directives or instructions outlining procedures, techniques, methods, processes, operations, activities, work flow, and like the, which are necessary to carry out programs or to achieve policy goals and objectives. These issuances may be of general or of limited scope yet in any case require definite compliance by those concerned. They are not addressed to any particular group of employees or offices because they are for general information, but those directly concerned with the compliance of these provisions are either definitely stated, or unmistakably implied threat.
- published: 14 Apr 2016
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