REVENUE REGULATIONS NO. 5-2012 issued on April 2, 2012 establishes the policy on the binding effect of rulings issued prior to the effectivity of the Tax Reform Act of 1997. All rulings issued prior to January 1, 1998 shall no longer have any binding effect. Consequently, these rulings cannot be invoked as basis for any current business transaction/s. Neither can these rulings be used as basis for securing legal tax opinions/rulings.