China Geo-Engineering Corp./ESR Construction & Development Corporation (Joint Venture)

May 19, 2020BIR RULING NO. JV-225-20Sec. 22 (B) of the NIRC;RR 14-02; RR 10-12; BIR Ruling No. 013-18China Geo-Engineering Corp./ESR Construction& Development Corporation (Joint Venture)8F Unit 801-B, Biopolis Bldg., Diosdado Macapagal Blvd.Pasay City, Metro ManilaAttention: AAA_______________Gentlemen :This refers to your letter dated September 9, 2019, requesting for a ruling that the joint venture between China Geo-Engineering (Phil.) Corporation and ESR Construction & Development Corporation formed for the purpose of undertaking the Construction of PR-06, Alicia-Malangas Road, Zamboanga Sibugay, under ADB Loan No. 3631-PHI: Improving Growth Corridors in Mindanao Road Sector Project (IGCMRSP), with Contract Identification No. 18Z00023 ("JV Project") is exempt from the two percent (2%) creditable withholding tax pursuant to Revenue Regulations (RR) No. 11-2018. HTcADCDocuments submitted disclosed that China Geo-Engineering (Phil.) Corporation/ESR Construction & Development Corporation Joint Venture ("JV"), with Tax Identification Number (TIN) 000-000-000-000 is an unincorporated joint venture formed to undertake the construction of the JV Project; that the JV is also registered with the Philippine Contractors Accreditation Board (PCAB) with Special Contractor's License No. FC-18-004 originally issued on July 11,...