Taxation Law: any law that arises from the
exercise of the taxation power of the state.
Types of Taxation laws:
1. Tax Laws: for assessment and collection
of taxes.
Examples: National Internal Revenue
Code. Tariff and Customs Code. Local
Tax Code.
2. Tax Exemption Laws: grant certain
immunity from taxation power.
Example: Minimum Wage Law, BMBE
Law, Cooperative Development Act.

III.
Revenue Memorandum rulings
 Rulings and interpretations of
the CIR to the provisions of the
Tax Code and other tax laws as
applied to specific set of facts,
with or w/o precedents
 The CIR may issue this rulings to
provide taxpayers guidance on
the tax consequences in specific
situations.
Note: BIR Rulings cannot
contravene duly issued RMRS.
IV.
Revenue Memorandum circulars
 issuances that publish pertinent
and applicable portions, as well
as amplifications, of laws, rules,
regulations and precedents
issued by the BIR and other
agencies/offices
Revenue bulletins
 Periodic issuances, notices and
announcements of the CIR that
consolidate the BIR’s position
on certain specific issues of law
in relation to the provision of
the tax code, relevant tax laws,
and other issuances for the
guidance of the public.
Sources of Taxation Law
I.
Constitution
II.
Statutes and Presidential Decrees
III.
Judicial Decisions or case laws
IV.
Executive Orders and Batas Pambansa
V.
Administrative Issuances
VI.
Local Ordinances
VII.
Tax Treaties and Conventions with
Foreign Countries
VIII.
Revenue Regulations
Types of Administrative Issuances
I.
Revenue Regulations
 Issuances signed by the
Secretary of Finance upon
recommendation of the
Commissioner of Internal
Revenue.
 Specify and define the rules and
regulations for the effective
enforcement of the provisions
of the NIRC and related
statutes.
 Formal pronouncements to
clarify the law and carry into
effect its general provisions by
providing details of
administration and procedure.
 It has the force and effect of a
law, but not intended to expand
or limit the application of the
law.
II.
Revenue Memorandum orders
Provide directives and
instructions, guidelines and
outline processes, operations
and procedures necessary in
the implementation of stated
policies, goals, objectives, plans
and program of Bureau in all
areas of operations except
auditing.
V.
VI.
BIR Rulings
 BIR Rulings are the official
position of the Bureau to
queries raised by taxpayers and
other stakeholders relative to
clarification and interpretation
of tax laws.
Note: Rulings are merely advisory or
information service to the taxpayers, none of
them is binding except to the addressee and
may be reversed by the BIR at any time.
Types of Rulings
a. VAT rulings
b. International