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.
Finality of Judgments: Why the CIR's Appeal in CIR v. Script2010, Inc. Was Denied
The Supreme Court denied the CIR's appeal in CIR v. Script2010, Inc., reaffirming that final and executory judgments can no longer be disturbed.
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.
Tax Assessment vs Tax Refund: Know Your Rights Under the Local Government Code
The Supreme Court clarifies when taxpayers may claim a refund under Section 196 instead of protesting an assessment under Section 195 of the Local Government Code.
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.
When Tax Disputes Between Government Agencies Must Be Settled Administratively
Supreme Court ruling on whether tax disputes between government agencies go to the CTA or administrative settlement under P.D. 242.
Local Tax Assessments After Corporate Restructuring: Who Pays?
Supreme Court rules on who bears local business tax liability when a government corporation's operations transfer by law to another entity.
Understanding Gross Neglect of Duty: A Landmark Ruling on Public Officials' Responsibilities
Explore the Supreme Court's landmark ruling on gross neglect of duty and what it means for public officials' responsibilities in the Philippines.
Inter-Company Loans and VAT: When Interest Income Is Not Taxable
Philippine Supreme Court ruling clarifies when interest on inter-company loans is exempt from VAT and how prescription periods apply.
When a Revenue Officer Lacks Authority: The LOA Requirement in Tax Audits
Philippine Supreme Court explains why a new Letter of Authority is required when tax investigations are reassigned to another revenue officer.
Letter of Authority Required When Reassigning Tax Audits: Supreme Court Ruling
Supreme Court nullifies tax assessments where audits were reassigned without a new Letter of Authority. Learn the rules.
Due Process in Tax Assessments: Strict Adherence to Notice Requirements
The Supreme Court nullified a deficiency tax assessment because the BIR issued the Final Assessment Notice before the taxpayer's 15-day period to reply to the Preliminary Assessment Notice lapsed.
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.
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.
Cable TV Franchise Tax: What the New Vision Ruling Means for Operators
The Supreme Court ruled that NTC-issued certificates of authority are administrative franchises subject to local franchise tax under the Local Government Code.
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.
Navigating Tax Assessments: The Importance of Timely Appeals in the Philippines
Learn why timing matters in Philippine tax disputes and how missing an appeal deadline can forfeit a taxpayer's right to challenge an assessment.
Understanding the Timely Filing of Appeals: A Crucial Lesson From Philippine Land Disputes
The Supreme Court clarifies the 30-day appeal period in tax disputes, using a land dispute analogy to explain finality and jurisdiction.
Navigating Tax Assessments: The Validity of Letters of Authority in the Philippines
Learn when a BIR Letter of Authority becomes invalid, the 30-day and 120-day rules, and how the Supreme Court ruled in AFP General Insurance.
Navigating Tax Law Conflicts: Understanding the Jurisdictional Limits of Courts in Tax Disputes
The Supreme Court clarifies the boundaries of judicial review in tax cases, emphasizing that courts cannot substitute their judgment for that of tax authorities.
Premium Tax vs Cost of Service: Defining Minimum Corporate Income Tax
Supreme Court clarifies which taxes count as "cost of services" in computing MCIT for insurance companies, and when DST applies to policy increases.
Due Process in Tax Assessments: When the BIR's Failure to Consider a Taxpayer's Protest Invalidates Assessment
The Supreme Court clarifies that the BIR's failure to consider a taxpayer's protest and evidence violates due process, rendering tax assessments null and void.
Philippine Ports Authority v. City of Davao: Jurisdiction and Forum Shopping in Real Property Tax Cases
Explains why the CTA, not the CA, has exclusive jurisdiction over real property tax appeals and why splitting remedies constitutes forum shopping.
Res Judicata and Due Process in Tax Sales: When a Prior Case Does Not Bar a New Suit
The Supreme Court clarifies when res judicata applies in tax delinquency sales and protects property owners' right to due process.
PD 242 and Intra-Government Tax Disputes: Who Decides When BIR Faces Another Agency?
Supreme Court clarifies that PD 242 governs disputes solely between government entities, giving the DOJ Secretary jurisdiction over BIR-PSALM VAT cases.