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By: Atty. Xela Leona D. Laqui on April 18,2024 Under Section 222 of the National Internal Revenue Code, as amended (“Tax Code”), the ten-year prescriptive period for the Commissioner of Internal Revenue (CIR) to assess tax applies in cases where a taxpayer files a false or fraudulent return with...

By: Atty. Sarah T. Ganto on April 5,2024 With the issuance of Revenue Memorandum Circular (“RMC”) No. 5-2024, as clarified by RMC No. 38-2024, on the taxation of cross-border services, another topic tackled by the said RMCs equally merits discussion: the taxation of reimbursements among multinational...

By: Atty. Lew Earvin Manarin on March 14,2024 The Corporate Recovery and Tax Incentives for Enterprises Act (the “CREATE Act”) introduced amendments to our National Internal Revenue Code (“Tax Code”) which were aimed to eliminate tax uncertainty, offer tax assistance to struggling enterprises...

By: Atty. Keanu P. Castañeda on March 7,2024 Republic Act No. 11976 otherwise known as the “Ease of Paying Taxes” (“EOPT”) amended Sections 204 and 229 of our National Internal Revenue Code, as amended (the “Tax Code”) and modified the rules and procedures on the claims for refund of erroneously...

By: Atty. Jigo P. Arevalo on February 28,2024 The world of international trade, particularly for agricultural products, can be a labyrinth of regulations and tariffs. Like many other countries, the Philippines navigates this intricate landscape using a system of Tariff-Rate Quotas (TRQs), specifically...

By: Atty. Nica Marsha V. Gasapo on February 22,2024. In Commissioner of Internal Revenue v. Toledo Power Corporation (G.R. No. 259309, February 13, 2023) (the “Toledo Case”), the Supreme Court overturned the findings of the Court of Tax Appeals (“CTA”) both in Division and En Banc, and held that...