Guidelines on BIR Requests for Rulings Process

No rulings are issued on matters declared as "No-Ruling Areas" under Revenue Bulletin Nos. 1-2003 and 2-2003.
Non-compliance with procedural requirements may lead to denial of rulings.
The Bureau does not provide tax planning advice or approve tax planning arrangements.
Issues resolvable through other processes (e.g., appeals) are not subject to rulings.
Rulings will not be issued if:
- A similar inquiry has already been directed to another BIR office.
- The matter is involved in pending litigation or investigation, audit, administrative protest, refund claim, issuance of tax credit, or collection proceedings involving the same or related taxpayers.

Hypothetical or "what if" questions involving speculative or assumed entities or transactions will not receive rulings.
No rulings on alternative or proposed transaction plans or supposed situations.

Requests must be sworn statements under oath by the taxpayer or authorized representative.
Must contain:
- Factual background: names, addresses, TINs of interested parties, business reasons, detailed transaction description.
- Issues or questions raised for confirmation.
- Legal grounds and supporting authorities.
- List of submitted documents.
- Affirmations regarding the absence of similar pending inquiries or cases and completeness of documents.
Requests must be addressed to the Chief, Law and Legislative Division, BIR National Office Building, Quezon City.

Include certified true copies of all material documents (e.g., contracts, wills, deeds, agreements).
Evidence of entitlement to exemption or incentive must be included.
Special Power of Attorney required if filed by a representative.
Original documents are not to be submitted.
Documents must be alphabetically labeled and properly organized.

Upon submission, no further communication with applicant is conducted except for written denial if incomplete.
Law and Legislative Division reviews and evaluates requests.
Denials due to insufficient documents are communicated in writing with reasons.
Complete requests are either approved or denied by issuance of ruling.
The Commissioner of Internal Revenue approves and signs rulings unless delegated.

Taxpayers may rely on valid rulings based on fully and accurately described transactions.
Rulings are not precedents for other taxpayers but indicate BIR’s stance on similar cases.
Rulings pertain only to internal revenue taxes; they do not cover local taxes, customs duties, or other taxes outside BIR jurisdiction.

Rulings may be revoked or modified if:
- Facts as presented are incorrect or differ from reality.
- Commissioner’s views change.