Denials by BIR-ITAD of Tax Treaty Relief Applications Based on Section 14 of Revenue Memorandum Order No. 72-2010

March 28, 2014DOF MEMORANDUMFOR:Secretary Cesar V. Purisima  Department of Finance   SUBJECT:Denials by BIR-ITAD of Tax Treaty Relief Applications Based on Section 14 of Revenue Memorandum Order No. 72-2010 The Bureau of Internal Revenue (BIR) issued Revenue Memorandum Order No. 72-2010, which provides guidelines on the processing of Tax Treaty Relief Applications (TTRAs) pursuant to existing tax treaties of which the Republic of the Philippines (RP) is a signatory of. A salient provision of said RMO is Section 14, which provides: "SEC. 14. When and Where to File the TTRA. — All tax treaty relief applications (updated BIR Forms Nos. 0901-D, 0901-I, 0901-R, 0901-P, 0901-T, 0901-O and 0901-C) relative to the implementation and interpretation of the provisions of Philippine tax treaties shall only be submitted to and received by the International Tax Affairs Division (ITAD). If the forms or any necessary documents are submitted to any other BIR Office, the application shall be considered as improperly filed.Filing should always be made BEFORE the transaction. Transaction for purposes of filing the TTRA shall mean before the occurrence...