Request for Review of Bureau of Internal Revenue Ruling No. 296-2014

December 18, 2019DOF OPINION NO. 017-19Atty. Antonio E. EscoberPanopio Escober and Associates Law Offices3rd Floor, AZPHI BuildingMa. Aurora corner E. Zobel StreetsPoblacion, Makati City SUBJECT : Request for Review of Bureau of Internal Revenue Ruling No. 296-2014 Dear Atty. Escober :This refers to the subject letter dated 06 April 2015 ("Request for Review") which you filed with this Department on behalf of your client Imperial Sky Garden Condominium Corporation ("Imperial Sky") to request for review of Bureau of Internal Revenue ("BIR") Ruling No. 296-2014 dated 24 July 2014 ("BIR Ruling").In particular, the Request for Review prays for the reversal of the BIR's finding that the transfer from China Banking Corporation ("Chinabank") to Imperial Sky of the land and common areas in the Imperial Sky Garden Condominium Project ("Imperial Sky Garden") is not covered by Revenue Memorandum Order ("RMO") No. 18-2009 and, hence, is subject to the 6% creditable withholding tax pursuant to Revenue Regulations ("RR") No. 2-1998, as amended. DETACaOn the other hand, as stated in your Request for Review, it is your main position...