January 6, 2020
BIR RULING NO. OT-001-20
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Sir :
This refers to your letter dated August 13, 2019 stating that Mitsubishi Heavy Industries Asia Pacific-Manila Branch ("MHIAP" for brevity) is a branch office of Mitsubishi Heavy Industries Asia Pacific based in Singapore; that MHIAP is organized and existing under the laws of the Republic of the Philippines since June 29, 2015; that MHIAP has submitted an Application for Registration as an ECOZONE IT Enterprise to the Philippine Economic Zone Administration (PEZA); and that in accordance with Revenue Memorandum Circular (RMC) No. 21-2007 dated March 5, 2007, you now request a ruling that a Certification from PEZA that an enterprise is a bona-fide PEZA registered enterprise and is entitled to the Income Tax Holiday and/or the five percent (5%) Tax on Gross Income automatically entitles a PEZA registered enterprise to tax incentives. CAacTH
In reply, please be informed that the issuance of BIR Ruling is not necessary since RMC No. 21-2007 dated March 5, 2007 merely prescribes the attachments to the Annual Income Tax Return (ITR) to be filed by...