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SyCip Salazar Hernandez & Gatmaitan
Before September 22, 2021, no. In the case of Saint Wealth Ltd. v. Bureau of Internal Revenue, the Supreme Court ruled that before the effectivity of Republic Act No. 11590, which was passed into law on September 22, 2021...
SyCip Salazar Hernandez & Gatmaitan
Yes. The Fiscal Incentives Review Board (FIRB) issued a Resolution dated September 14, 2022, which further extended the effect of FIRB Resolution No. 17-2022 which temporarily allows RBEs...
SyCip Salazar Hernandez & Gatmaitan
Generally, no. In City of Davao v. ARC Investors, Inc., (G.R. No. 249668 (Resolution), July 13, 2022), the Supreme Court noted that while local government units ("LGU") have the power to impose local
SyCip Salazar Hernandez & Gatmaitan
Yes. In Bureau of Internal Revenue vs. Samuel Cagang (G.R. No. 230104, March 16, 2022), the Supreme Court upheld the deficiency withholding tax assessment against a taxpayer,...
SyCip Salazar Hernandez & Gatmaitan
No. The stock transaction tax is not an income tax but a percentage tax. The exclusion from gross income under Section 32(B)(7)(a) of the NIRC applies only to income tax under Title II of the...
SyCip Salazar Hernandez & Gatmaitan
No. The Bureau of Internal Revenue's (BIR's) collection efforts are initiated by distraint, levy, or court proceeding and not upon issuance of a Final Decision on Disputed Assessment (FDDA).
SyCip Salazar Hernandez & Gatmaitan
On March 2, 2022, the President signed into law Republic Act (R.A.) No. 11647 which amends the three-decade old Foreign Investments Act of 1991 (FIA). R.A. No. 11647 aims to attract...
SyCip Salazar Hernandez & Gatmaitan
Section 267 of the Local Government Code of 1991 (LGC) provides, in part, that "[n]o court shall entertain any action assailing the validity of any sale at public auction of real property or ...
SyCip Salazar Hernandez & Gatmaitan
If the 50% threshold is breached, the applicable income tax rate is the 25% regular corporate income tax rate.
SyCip Salazar Hernandez & Gatmaitan
On March 2, 2022, the President signed into law Republic Act (R.A.) No. 11647 which amends the three-decade old Foreign Investments Act of 1991 (FIA). R.A. No. 11647 aims to attract, ...
SyCip Salazar Hernandez & Gatmaitan
Prior to the implementation of the Corporate Recovery and Tax Incentives for Enterprises Act (the CREATE Act), the Philippines adhered to the "cross-border doctrine", under which ecozones and freeport zones...
SyCip Salazar Hernandez & Gatmaitan
Where the withholding agent applies the regular tax rate, the non-resident taxpayer may seek tax treaty relief by filing an application with the BIR.
SyCip Salazar Hernandez & Gatmaitan
Is there an exception to the general rule that findings of fact of the Court of Tax Appeals (CTA) are regarded as final, binding, and conclusive upon the Supreme Court?
SyCip Salazar Hernandez & Gatmaitan
On December 10, 2021, the President signed into law Republic Act (R.A.) No. 11635 amending Section 27(B) of the National Internal Revenue Code, as amended (Tax Code).
SyCip Salazar Hernandez & Gatmaitan
SyCipLaw's Tax Department has prepared an international edition of its Tax Issues and Practical Solutions (T.I.P.S.) for the last quarter of 2021.
SyCip Salazar Hernandez & Gatmaitan
1. Is a letter informing the Bureau of Internal Revenue (BIR) that the taxpayer is "in the process of compiling necessary documentation" a valid protest?
SyCip Salazar Hernandez & Gatmaitan
SyCipLaw Tip: Once an assessment for national internal revenue tax is issued, the proper remedy would be to timely protest or appeal the assessment in accordance with the revenue regulations...
SyCip Salazar Hernandez & Gatmaitan
SyCipLaw's Tax Department has prepared an international edition of its Tax Issues and Practical Solutions (T.I.P.S.) for the third quarter of 2021.
SyCip Salazar Hernandez & Gatmaitan
SyCipLaw's Tax Department has prepared an international edition of its Tax Issues and Practical Solutions (T.I.P.S.) for the third quarter of 2021.
SyCip Salazar Hernandez & Gatmaitan
Taxpayers now have until June 14, 2023, to avail themselves of the Estate Tax Amnesty. Republic Act No. 11569, titled "An Act Extending the Estate Tax Amnesty and for Other Purposes...
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