Prescribing the Procedure and Guidelines for the Proper Handling of Request for Rulings

2003REVENUE BULLETIN NO. 01-03NO-RULING AREAS — 001SUBJECT:Prescribing the Procedure and Guidelines for the Proper Handling of Request for Rulings Which are Determined Hereunder as "No-Ruling Areas", and Providing the Initial List of "No-Ruling Areas"   TO:All Internal Revenue Officers and Others Concerned SECTION 1. Background and Scope. — Section 4 of the Tax Code of 1997 grants the Commissioner of Internal Revenue the exclusive and original jurisdiction to interpret the provisions of the Tax Code of 1997 and other tax laws. On the other hand, the Legal Service, particularly the Law Division and the International Tax Affairs Division, and the Legal Divisions in the Revenue Regions, as well as the VAT Review Committee reconstituted under Revenue Special Order No. 413-2001 dated August 31, 2001, are responsible for preparing the rulings to be signed and issued by the appropriate revenue official. The ruling function is limited to the determination of purely legal issues, as opposed to questions of fact. Likewise, the ruling function need not be exercised where the law, rule or regulation is clear, thereby dispensing...