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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...

By: Atty. Euney Marie J. Mata-Perez on February 2,2024 In my interview with Business Outlook last Thursday, January 24, 2024, I was asked if we are competitive as a country from a taxation point of view.  I mentioned that while there have been efforts, through tax reforms, to make the...

By: Atty. Euney Marie J. Mata-Perez on January 25,2024 In its Revenue Memorandum Circular No. 5-2024 (RMC 5-2024), the Bureau of Internal Revenue (BIR) is espousing new rules regarding the situs or source of income.  RMC 5-2024 sprung from the decision of the Supreme Court in Aces Philippines Cellular Satellite...

By: Atty. Euney Marie J. Mata-Perez on January 18,2024 In taxation of foreign corporations in the Philippines, the determination of source of income is key, and this determination has taken a significant turn lately. Taxation is an inherent power of sovereignty of a state. For a state to exercise such...

By: Atty. Euney Marie J. Mata-Perez on January 11,2024 The Philippine tax scene is abuzz again with the passage of Republic Act No. 11976, or the Ease of Paying Taxes (EOPT) Act on January 5, 2024.  The main objective of the Act is to provide a healthy environment for the...

By: Atty. Euney Marie J. Mata-Perez on January 4,2024 Happy new year everyone!  Time flies so fast, and we are now in 2024.  It has been four years that our law firm, Mata-Perez, Tamayo & Francisco has been contributing weekly to this column, More to Follow Column of The Manila...

By: Atty. Nica Marsha Gasapo on December 21,2023 As the curtains fall on another trip around the sun, it is important to dissect the events that unfolded in the past months. The conclusion of the year is not merely a time for reflective musings; it also a strategic and opportune...