Request for Review of Bureau of Internal Revenue Ruling No. ITAD 108-18

May 27, 2019DOF OPINION NO. 006-19Atty. Gerardo June T. BuanCounsel for Petitioner/AppellantBuan & Temprosa Law OfficesUnit 1005 & 1006, Cityland Condominium 10, Tower 1156 H.V. Dela Costa Street, Salcedo VillageMakati, Metro Manila, Philippines SUBJECT : Request for Review of Bureau of Internal Revenue Ruling No. ITAD 108-18 Dear Atty. Buan :This refers to the subject letter dated 12 December 2018 ("Request for Review") which you filed with this Department on behalf of Universal International Music B.V. ("UIM"), to request the review of Bureau of Internal Revenue ("BIR") Ruling No. ITAD 108-18 dated 23 October 2018, which ruled that donor's tax is due on the transfer of MCA Music, Inc. ("MCA") Shares from Universal Music International Holding B.V. ("UMIH") to UIM pursuant to the merger of UMIH to UIM. SaCIDTUIM is a non-resident foreign corporation duly organized and existing under the laws of the Netherlands. UIM is not registered in the Philippines as a corporation or as a partnership. UIM is also not licensed to do business in the Philippines.On the other hand, MCA is a...