SDS Co., a domestic corporation, acquired 11 parcels of land from the
Asset Privatization Trust, the government agency in charge in disposing the
government’s non-performing assets.
Although the parcels of land are located in various localities, SDS Co.
filed all pertinent tax returns and paid the corresponding taxes with BIR Pasay
for the issuance of the Certificates Authorizing Registration (CARs).
SDS Co. requested for a ruling that the CARs be issued by BIR Pasay for
the transfer of the subject parcels of land.
The BIR ruled that BIR Pasay cannot issue the CARs to SDS Co. since
under Section 5 of RR No. 5-09, CARs shall be issued by the Revenue District
Office of the BIR district having jurisdiction over the place where the
property being transferred is located.
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