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By: Atty. Cara Angela N. Flores on April 25,2024 Section 203 of the National Internal Revenue Code, as amended (the “Tax Code”), entitled “Period of Limitation Upon Assessment and Collection”, provides that taxes shall be assessed within three (3) years after the last day prescribed by law for the filing...

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 intent...

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 enterprises. RMC No. 5-2024...

By: Atty. Euney Marie J. Mata-Perez on March 21,2024 On March 15, 2024, the Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular No. (RMC) No. 38-2024 clarifying its earlier pronouncements in RMC No. 5-2024 on the taxation of cross-border transactions.  To recall, in Aces Philippines Cellular Satellite Corp. v....

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 affected by the COVID-19 pandemic, and streamline...

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 in-quota and out-quota rates. Understanding these terms...

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 payments...

By: Atty. Euney Marie J. Mata-Perez on February 15,2024 In their position paper dated February 13, 2024, representatives of certain private sector groups requested Bureau of Internal Revenue (BIR) Commissioner Romeo Lumagui to review, revisit, and reconsider the provisions of Revenue Memorandum Circular (RMC) No. 5-2024 dated January 10, 2024,...