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.

Showing 1–13 of 13 articles for “court of tax appeals”

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Feb 9, 2025 tax law bir assessment waivers prescription cir v. telstar

Defective Tax Waivers: Supreme Court Voids BIR Assessment Against Telstar

Supreme Court voids BIR deficiency assessment against Telstar due to defective waivers and lack of demand for payment, reinforcing strict rules on prescriptive periods.

Aug 18, 2024 vat refund input tax tax law supreme court bir cta

VAT Refund Timelines: Supreme Court Clarifies the 120-Day Rule in Dohle Shipmanagement

The Supreme Court clarifies when the 120-day VAT refund period starts, giving taxpayers control over the timeline for judicial claims.

May 12, 2024 tax law tax credit irrevocability rule corporate taxation nirc

Irrevocability of Tax Credit Options: A Guide for Philippine Corporations

Philippine corporations must choose carefully between refunds and tax credit carry-over—once chosen, the option is irrevocable under the NIRC.

Nov 12, 2023 tax evasion civil liability tax assessment court of tax appeals bir criminal law

When Tax Assessments Are Not Required: Civil Liability in Philippine Tax Evasion Cases

Philippine Supreme Court clarifies when a formal BIR tax assessment is not required to hold taxpayers civilly liable in criminal tax evasion cases.

Oct 3, 2023 tax law bir assessment letter of authority due process tax audit

Letter of Authority vs. Letter Notice: When a BIR Tax Assessment Is Void

The Supreme Court ruled that a BIR Letter Notice cannot substitute for a Letter of Authority—assessments without a valid LOA are void.

Apr 25, 2021 documentary stamp tax gross receipts tax special savings accounts banking taxation philippine veterans bank tax law

DST and GRT on Special Savings Accounts: Philippine Veterans Bank Ruling

The Supreme Court ruled special savings accounts are subject to documentary stamp tax and that final withholding taxes count toward gross receipts tax.

Feb 25, 2020 tax law capital gains tax share swap nirc supreme court corporate restructuring

Tax-Free Share Swaps in the Philippines: The Co Ruling and CGT Exemptions

The Supreme Court's Co ruling clarifies when share swaps are tax-free under (C)(2) of the NIRC, saving businesses millions.

Jun 4, 2017 tax law tax assumption tax exemption executive agreements bir refunds international agreements

Tax Assumption vs. Tax Exemption: The Mitsubishi Ruling on Government-Promised Tax Relief

The Supreme Court clarifies when a government's promise to assume taxes binds the state—and when it doesn't—in this landmark Philippine tax case.

Nov 25, 2014 peza real property tax local government taxation tax exemption instrumentality of national government

PEZA Tax Exemption: Instrumentality of National Government and Real Property Tax

Supreme Court rules PEZA is exempt from real property tax as an instrumentality of the national government, clarifying local taxing limits.

Oct 19, 2010 zonal valuation capital gains tax documentary stamp tax real property tax bir supreme court ruling

Zonal Valuation vs. Actual Use: What Governs CGT and DST on Property Sales

The Supreme Court rules that existing zonal valuations, not actual property use, govern capital gains tax and documentary stamp tax computations.

Jul 13, 2006 tax law bir rulings non-retroactivity vat taxpayer rights

Non-Retroactivity of BIR Rulings: The Benguet Case and Taxpayer Protection

Learn how the Supreme Court protects taxpayers from retroactive BIR rulings, based on the landmark Benguet Corporation case.

Apr 23, 2003 tax law advertising expenses deductions nirc capital expenditure income tax

Advertising Expenses and Tax Deductions: Ordinary vs. Capital Outlay in the Philippines

Philippine tax law on advertising deductions: when a colossal ad spend becomes a capital outlay, not an ordinary expense.

Nov 16, 1999 civil procedure judicial admissions palpable mistake stipulation of facts tax litigation rules of court

Palpable Mistakes in Stipulations: Correcting Factual Errors in Philippine Courts

Philippine courts may correct factual errors in stipulations when made through palpable mistake, as shown in Atlas Consolidated Mining v. CIR.