June 2, 2020
BIR RULING NO. S40-292-20
Section 40 (C) (2) & (6) (b), Tax Code of 1997, as amended;
BIR Ruling No. 214-12; BIR Ruling No. 075-18
Carag Zaballero Llamado &
Abiera Law Offices
Suite 2602, 26th Floor, The Atlanta Centre
No. 31 Annapolis Street, Greenhills
1506 San Juan, Metro Manila
Attention: AAA
BBB
Gentlemen :
This refers to your letter dated 7 August 2013 requesting for a confirmation of your opinion that the statutory merger of ABS-CBN Film Productions, Inc. (AFPI) with Roadrunner Network, Inc. (RNI), with the former as the surviving corporation, be qualified as a tax free merger under Sections 40 (C) (2) and (C) (6) (b) of the National Internal Revenue Code (NIRC) of 1997, as amended.
BACKGROUND
It is represented that AFPI is a corporation duly organized and existing under Philippine laws with principal office address at Sgt. Esguerra Avenue corner Mother Ignacia Street, Quezon City. At the time of the merger, it had an authorized capital stock of ____________________ Pesos (P__________) divided into Fifty Thousand (50,000) common shares with a par value of ____________________ Pesos (P__________) per share. The amount of capital...
