Legal Insights
Plain-language guides and case briefs on Philippine law — researched from the firm's law library of 184,000+ statutes, Supreme Court decisions, and agency issuances, and written so non-lawyers can understand and act on them.
Substantiation of Tax Deductions: Proper Documentation Under Philippine Tax Law
Philippine law requires proper documentation for tax deductions, including PWD discounts. Learn the rules and substantiation requirements.
Dividends vs Capital Gains: Taxing Share Redemptions Under the RP-US Treaty
Supreme Court rules on whether share redemption proceeds are dividends or capital gains under Philippine tax law and the RP-US Tax Treaty.
Tax Evasion and Probable Cause: BIR v. Manila Home Textile Explained
The Supreme Court clarifies the standard of probable cause in tax evasion cases and the burden on the BIR in preliminary investigations.
Void Tax Assessment Decisions: Protecting Taxpayer Rights to Due Process
When a Final Decision on Disputed Assessment lacks factual basis, it is void—but the underlying tax assessment may survive.
Tax Sales and Due Process: Protecting Property Rights in the Philippines
Philippine Supreme Court ruling on tax sales, due process, and property rights protection for landowners and buyers.
Understanding Documentary Stamp Tax on Trust Agreements: Insights from a Landmark Philippine Case
A Philippine Supreme Court ruling clarifies when documentary stamp tax applies to trust agreements and the evidence needed for tax refund claims.
PEZA Exempt From Local Property Taxes: Key SC Ruling Explained
The Supreme Court ruled PEZA is exempt from real property taxes as a government instrumentality. Learn the legal basis and implications.
Excise Tax Refunds for Petroleum Sold to International Carriers: Shell Ruling Explained
The Supreme Court clarifies when domestic petroleum manufacturers can claim excise tax refunds for fuel sold to international carriers.
VAT Refunds: Strict Compliance With the 120+30 Day Rule and Invoicing Requirements
Philippine Supreme Court clarifies the mandatory 120+30 day rule for VAT refund claims and invoicing requirements in Commissioner of Internal Revenue v. Toledo Power Company.
Corporate Authority and Double Taxation: Lessons from Swedish Match Philippines
Supreme Court clarifies rules on corporate authority in tax refund cases and double taxation under local business tax ordinances.
Navigating VAT Refund Claims: Prescriptive Periods and Equitable Estoppel in Philippine Tax Law
Philippine Supreme Court clarifies the two-year prescriptive period for VAT refund claims and the mandatory 120-day waiting period before judicial appeal.
Tax Refund or Tax Credit Carry Over: Understanding Irrevocability in Philippine Tax Law
The Supreme Court explains why choosing the carry-over option for excess income tax credits is irrevocable under the National Internal Revenue Code.
Unutilized Creditable Withholding Tax: Proving Claims for Refund or Tax Credit
The Supreme Court clarifies what a taxpayer must prove to claim a refund of unutilized creditable withholding taxes, and what need not be proven.
Due Process in Philippine Tax Assessments: The Critical Role of the Preliminary Assessment Notice
Philippine tax assessments require a Preliminary Assessment Notice; without it, the assessment is void for denying due process.
Local Tax Injunctions: Balancing Government Revenue and Taxpayer Rights in the Philippines
Philippine Supreme Court ruling on when courts may enjoin local tax collection, balancing government revenue needs with taxpayer rights.
VAT Refund Eligibility Zero Rated Sales and the San Roque Power Case
A look at the San Roque Power case, clarifying VAT refund eligibility for zero-rated sales under Philippine tax law.
Compromise Agreements in Philippine Tax Cases: The Supreme Court's Approval in California Manufacturing
When can a taxpayer compromise local tax liabilities? The Supreme Court's ruling in California Manufacturing explains the binding effect of judicial compromises.
Tax Evasion vs Deficiency: When Criminal Charges Can Proceed Without Prior Assessment
Philippine Supreme Court clarifies when the BIR can file criminal tax evasion charges without a prior formal assessment, distinguishing deficiency assessments from criminal prosecution.
Real Property Tax: Who Is the Actual User in a BOT Agreement?
Philippine Supreme Court ruling on real property tax exemption under a Build-Operate-Transfer agreement and who qualifies as actual user.
Taxing Telecommunications: No Exemption Without Explicit Grant
The Supreme Court rules that the phrase "exclusive of this franchise" in RA 7678 does not exempt Digitel's real properties from real property tax.
Tax Credit Certificates: Good Faith Transferees Protected Against Fraudulent Issuance
Supreme Court rules transferees in good faith and for value of tax credit certificates cannot be made to pay taxes again when the certificates are later canceled for fraud.
Compromise Agreements and Redemption Rights in Philippine Tax Delinquency Sales
Supreme Court ruling on compromise agreements, tax delinquency redemption, and substantial compliance in Philippine property law.
Accrual Accounting and the All-Events Test: Deducting Business Expenses in Philippine Tax Law
When can a business deduct expenses under accrual accounting? The Supreme Court explains the all-events test in this Philippine tax case.
Situs of Service Determines Income Tax Liability for Nonresident Aliens in the Philippines
Philippine Supreme Court rules that for nonresident aliens, income tax depends on where services are actually rendered, not where the payor resides.