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.
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Philippine Taxation: Source of Income for Satellite Communication Services
Supreme Court rules satellite air time fees paid to non-resident foreign corporation are Philippine-sourced income subject to final withholding tax.
Partial Summary Judgments: When Grave Abuse of Discretion Opens the Door to Certiorari
The Supreme Court clarifies when a partial summary judgment may be assailed via certiorari, and why a tax declaration case involving BCDA fell under grave abuse of discretion.
Tax Declarations and Property Ownership: When a Summary Judgment Oversteps
The Supreme Court clarifies when a partial summary judgment ordering a tax declaration constitutes grave abuse of discretion, and the proper remedy to challenge it.
Executive Authority vs Judicial Review: Resolving Tax Disputes Between Government Entities
The Supreme Court rules that tax disputes between executive agencies must first undergo administrative settlement, not judicial review.
When Tax Rulings Become Final: Prohibition, Forum Shopping, and the Hierarchy of Courts
The Supreme Court clarifies when a writ of prohibition may be filed directly with the Court of Appeals despite the hierarchy of courts rule.
VAT Refund Claims: Establishing Zero-Rated Sales as a Prerequisite
The Supreme Court clarifies that unutilized input VAT refunds under Section 112(A) require proof of zero-rated sales in the same taxable period.
Local Business Tax on Dividends and Interest Earned by Holding Companies
Supreme Court ruling on when holding companies are exempt from local business tax on dividends and interest income under the Local Government Code.
Taxing Transit: LRTA Exemption and the Public Good
The Supreme Court ruled the Light Rail Transit Authority is a government instrumentality exempt from real property tax, resolving conflicting rulings.
Candidate Eligibility: No Automatic Disqualification for Unpaid Taxes Absent Express Court Order
Supreme Court clarifies that unpaid taxes do not automatically disqualify a candidate absent an express penalty in a final court judgment.
Condominium Dues and VAT: Supreme Court Clarifies Taxability of Association Fees
The Supreme Court confirms that condominium association dues are not subject to VAT, income tax, or withholding tax.
Taxpayers May Await Commissioner's Decision Before Appealing BIR Assessments to CTA
Supreme Court clarifies taxpayers may await the Commissioner's ruling on a protested BIR assessment before filing an appeal with the Court of Tax Appeals.
Tax Liens vs Judgment Credits: Priority Disputes in Philippine Law
Supreme Court ruling on when a tax lien beats a judgment creditor's levy on real property under the National Internal Revenue Code.
Tax Collection Prescription: CIR's Collection Efforts Barred by Three-Year Period
Supreme Court affirms CTA ruling that the CIR's right to collect deficiency taxes prescribed after three years from assessment notice.
Beneficial Use Doctrine: Who Pays Real Property Tax on Government-Owned Land
When government property is leased to a private entity, the beneficial use doctrine makes the lessee liable for real property tax. Learn the rule.
Tax Amnesty Limits: Withholding Tax Liabilities and Corporate Officer Liability
The Supreme Court clarifies that tax amnesty under RA 9480 does not cover withholding tax liabilities, and corporate officers may still face prosecution.
Notarial Duty to Verify Identity: Lessons from Dionisio v. Padernal
Notarization is not a mechanical act. A notary must verify identity using competent evidence—not community tax certificates—or face sanctions.
VAT Refund Claims: The Window Period Exception to the 120-Day Rule
Learn how the Supreme Court applied the window period exception in VAT refund claims, allowing taxpayers to file judicial claims without waiting for the 120-day period.
Navigating Tax Refund Deadlines: The 120-Day Rule and Its Window Period Exception
Learn how the Supreme Court clarified the 120+30 day rule for VAT refund claims and the window period exception under BIR Ruling No. DA-489-03.
Navigating Tax Exemptions for Government-Owned Properties in the Philippines: Insights From a Landmark Case
Learn how the Supreme Court clarified tax exemptions for government-owned properties in the Philippines through a landmark ruling.
Tax Refund Claims: Why Judicial Claims Stand Independently of Administrative Proceedings
The Supreme Court clarifies that a judicial tax refund claim before the CTA is not precluded by defects in the administrative claim filed with the BIR.
Tax Assessment Validity: Waivers and Due Dates Under Scrutiny
The Supreme Court nullified BIR deficiency assessments for First Gas Power due to defective waivers and missing due dates, clarifying prescriptive period rules.
Prescription in Tax Assessments: Waivers Must Be Strictly Compliant for Validity
Waivers of the tax prescription period are strictly construed. Missing the BIR's date of acceptance voids them, and assessments without due dates fail.
Waiver Validity and Estoppel: When Taxpayers Cannot Question Defective BIR Waivers
Philippine Supreme Court ruling on defective waivers of prescription, taxpayer estoppel, and BIR assessment periods explained in plain language.
Navigating VAT Refund Claims: Due Process in Philippine Tax Courts
Learn how the Supreme Court protects taxpayers' due process rights in VAT refund claims, from the 120-day rule to document submission standards.