RMC No. 22-2012: Clarifies the implementation of Revenue Regulations No. 5-2012

Key points

1. No use as precedent. Taxpayers may not use these rulings as precedent to secure rulings for current business transactions or to support their position against an assessment.
2. No use by BIR lawyers. BIR action lawyers may not use these rulings in issuing new rulings on requests involving current business transactions.
3. Limited validity. The rulings remain valid only for the taxpayer who was issued the ruling and only for the specific transactions it covers.
4. When validity ends. They stay valid unless the taxpayer is expressly notified of revocation, or unless the legal basis for the ruling has been repealed or amended in the current Tax Code.

Who is affected

• Taxpayers holding BIR Rulings issued before Jan. 1, 1998
• BIR action lawyers

Deadlines and effectivity

• Rulings issued prior to Jan. 1, 1998