2003

REVENUE ADMINISTRATIVE ORDER NO. 01-03

SUBJECT : Addendum to Revenue Delegation Authority Order (RDAO) No. 5-2003

dated June 6, 2003 re: Delegation of Authority to Sign Documents and
Correspondence on Human Resource Management Concerns

TO : All Internal Revenue Officials and Employees, and Others Concerned

STATEMENT OF POLICY :
It is the recognized policy under this Order that the power to interpret the
provisions of the Tax Code of 1997 (Tax Code) and other tax laws is under the exclusive
and original jurisdiction of the Commissioner of Internal Revenue, subject to review by
the Secretary of Finance, as provided for in Section 4 of the Tax Code.
The Bureau of Internal Revenue is under the supervision and control of the
Department of Finance as provided for in Section 2 of the Tax Code and Book IV, Title II,
Chapter 4, Section 18 of the Administrative Code of 1987.
There is a need for uniformity of rulings and issuances in the interpretation and
application of the provisions of the Tax Code and other tax laws.
SECTION 1. Scope. — This Revenue Administrative Order (RAO) shall, in general,
apply to all revenue rulings and issuances of the Bureau of Internal Revenue that pertain
to the implementation of the provisions of the Tax Code and other tax laws, and shall
include the following:
a) Rulings of first impressions;
b) Rulings with established precedents;
c) Revenue Memorandum Rulings (RMR)
d) Revenue Bulletins (RB)
e) Revenue Travel Assignment Order (RTAO)
f) Revenue Special Order (RSO)
g) Revenue Memorandum Circular (RMC)
h) Revenue Memorandum Order (RMO)
i) Revenue Audit Memorandum Order (RAMO)
j) Revenue Delegation of Authority Order (RDAO); and
k) Revenue Administrative Order (RAO)
SECTION 2. Review Power of the Secretary of Finance. — In accordance with
Section 4 of the Tax Code, the Secretary of Finance shall have the power to a rm,
revise, modify or set aside rulings and issuances of the Bureau of the Internal Revenue
concerning the implementation and application of the provisions of the Tax Code and
other tax laws.

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 SECTION 3. Classi cation of BIR Rulings and Issuances . — The following terms
shall have the meaning described below:
a) Rulings of rst impression — These refer to the rulings, opinions and
interpretations of the Commissioner of Internal Revenue with respect
to the provisions of the Tax Code and other tax laws without
established precedent, and which are issued in response to a speci c
request for ruling led by a taxpayer with the Bureau of Internal
Revenue. Provided, however, that the term shall include reversal,
modification or revocation of any existing ruling.
b) Rulings with established precedents — These refer to mere reiteration of
previous rulings, opinions and interpretations of the Commissioner, as
delegated to duly authorized internal revenue o cers ( i.e., Deputy
Commissioner, Legal and Inspection Group; Assistant Commissioner,
Legal Service; Regional Directors) that are issued in response to a
speci c request for ruling led by a taxpayer with the Bureau of
Internal Revenue.ASDTEa

c) Revenue Memorandum Rulings (RMR) — These refer to the rulings,

opinions and interpretations of the Commissioner of Internal Revenue
with respect to the provisions of the Tax Code and other tax laws, as
applied to a speci c set of facts, with or without established
precedents, and which the Commissioner may issue from time to
time for the purpose of providing taxpayers guidance on the tax
consequences in specific situations.
d) Revenue Bulletins (RB) — These refer to periodic issuances, notices and
o cial announcements of the Commissioner of Internal Revenue that
consolidate the Bureau of Internal Revenue's position on certain
speci c issues of law or administration in relation to the provisions of
the Tax Code, relevant tax laws and other issuances for the guidance
of the public.
e) Revenue Travel Assignment Orders (RTAO) — These orders assign
revenue personnel to speci c functions in speci c units. Travel
assignment orders speci cally mention the names of revenue
personnel concerned.
f) Revenue Special Orders (RSO) — Instructions or directives for the
accomplishment of special assignments or missions of signi cance
which are temporary in nature or for a de nite period of time. These
issuances speci cally mention the personnel or units of organization
concerned.
g) Revenue Memorandum Circulars (RMC) — These issuances shall
disseminate and embody pertinent and applicable portions, as well as
amplifications of the rules, precedents, laws, regulations, opinions and
other orders and directives issued by or administered by the
Commissioner of Internal Revenue, and by o ces and agencies other
than the Bureau of Internal Revenue, for the information, guidance or
compliance of revenue personnel.

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 h) Revenue Memorandum Orders (RMO) — These are directives or
instructions outlining procedures, techniques, methods, processes,
operations, activities, work ow, and the like, which are necessary to
carry out programs or to achieve policy goals and objectives. These
issuances may be of general or of limited scope yet in any case
require de nite compliance by those concerned. They are not
addressed to any particular group of employees or o ces because
they are for general information, but those directly concerned with the
compliance of these provisions are either de nitely stated, or
unmistakably implied thereat.
i) Revenue Audit Memorandum Orders (RAMO) — These refer to the uniform
audit procedures to be observed by revenue o cers in the conduct of
audit of tax cases and in their submission of reports of investigation.
j) Revenue Delegation of Authority Orders (RDAO) — These refer to the
functions delegated by the Commissioner to revenue o cers in
accordance with law.
k) Revenue Administrative Orders (RAO) — These refer to matters that deal
strictly with more or less permanent administrative set-up of the
Bureau. Delineation of organizational structures, statements of
functions and/or responsibilities, de nitions and delegations of
authority, sta ng and personnel requirements, standards of
performance, establishment of Bureau-wide programs, installation of
systems, and the like, are most likely subject matter of Revenue
Administrative Orders. These issuances are for general guidance,
compliance and/or information.
SECTION 4. Validity of Rulings and Issuances. — All rulings and issuances of the
Commissioner of Internal Revenue that pertain to the implementation and interpretation
of the Tax Code and other tax laws are valid, unless revoked, reversed, modi ed, or
superseded by the Secretary of Finance pursuant to Department Order No. 23-01.
SECTION 5. Effectivity. — This Revenue Administrative Order shall take effect
immediately.

(SGD.) GUILLERMO L. PARAYNO, JR.

Commissioner of Internal Revenue

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