RMO No. 11-2010: Prescribes the policies and guidelines on the monitoring, review and determination of the tax consequences of “Big-Ticket Items”

Key points

1. What is a Big-Ticket Item. A transaction is a BTI if the amount exceeds P 200,000,000, measured per single and unrelated event or transaction without adding up several unrelated ones. It is also a BTI if it involves a request for ruling filed with the BIR where the transaction amount is over P 1,000,000.
2. Offices responsible. The Large Taxpayers Service (LTS) – Regular, LTS – Excise and the Enforcement Service monitor BTIs. They communicate with the concerned taxpayers within 5 working days from the date of the transaction or from the date of discovery.
3. Access to Records. The Assistant Commissioner of the responsible office sends an Access to Records letter to the taxpayer. Submission of the requested documents by the deadline must be strictly enforced, and failure to comply should result in available sanctions, including a subpoena duces tecum.
4. Ruling requests. For ruling requests on transactions over P 1,000,000.00, the BIR legal office that receives the request gives a copy to the BIR office with jurisdiction over the taxpayer. That office requests information using the Access to Record form and reports its evaluation to the legal office not later than 15 working days from receipt of the documents.

Who is affected

• Large Taxpayers Service – Regular and Excise
• Enforcement Service
• Taxpayers with Big-Ticket Item transactions

Deadlines and effectivity

• Contact taxpayer within 5 working days from transaction or discovery
• Evaluation report within 15 working days from receipt of documents