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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...

Elevating the spirit of womanhood and national pride, this month’s flag raising ceremony is a standout event. The Stop and Salute Flag-Raising Ceremony is a monthly program of the National Parks Development Committee (NPDC) and Salute To A Clean Flag Movement, in cooperation with the National Historical Commission of the...

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,...

By: Atty. Nica Marsha V. Gasapo on February 8,2024 The Financial Rehabilitation and Insolvency Act (“FRIA”) or Republic Act No. 10142 was enacted with the aim of offering debtors an avenue to preserve and maximize the value of their assets and prioritize claims; and, at the same time, ensuring fair...