REVENUE MEMORANDUM CIRCULAR NO. 22-2012 issued on May 7, 2012 clarifies the implementation of Revenue Regulations No. 5-2012, to wit:
         a. All BIR Rulings issued prior to Jan. 1, 1998 are not to be used as precedent by any                             taxpayer as a basis to secure rulings for themselves for current business transaction/s or                 in support of their position against any assessment.
         b. All BIR Rulings  issued prior to Jan. 1, 1998 are not to be used by any BIR action lawyer in                  issuing new rulings for request for rulings involving current business transaction/s.
         c. However, BIR Rulings issued prior to Jan. 1, 1998 remains to be valid but only:
                     i. to the taxpayer who was issued the ruling; and
                    ii. Covering the specific transaction/s which is the subject of the same ruling.
        d. BIR Rulings issued prior to Jan. 1, 1998 shall remain valid as mentioned above, unless                        expressly notified of its revocation or unless the legal basis in law for such issuance has                  already been repealed/amended in the current Tax Code.