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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Unlocking VAT Refunds for Zero-Rated Sales: The Attributability Requirement in Philippine Tax Law
The Supreme Court clarifies that input VAT need not be directly and entirely attributable to zero-rated sales for refund claims, easing the path for VAT-registered taxpayers.
Excise Tax on Alkylate: When Tax Laws Are Interpreted in Favor of Taxpayers
The Supreme Court ruled alkylate is not subject to excise tax under the NIRC, applying strict construction of tax laws in favor of taxpayers.
Understanding TAX Assessments THE Importance OF Clear Factual Basis IN Philippine TAX Law
The Supreme Court clarifies that tax assessments must rest on solid factual grounds, not mere assumptions, to be valid and enforceable.
Navigating Tax Assessments: Understanding the Limits of Declaratory Relief in Philippine Tax Law
The Supreme Court clarifies when declaratory relief cannot be used to challenge tax assessments, reinforcing the rule against enjoining tax collection.
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.
Zero-Rated VAT on Export Sales: Why Actual Exportation Matters Under Philippine Tax Law
Philippine Supreme Court clarifies that BOI certifications alone do not prove zero-rated VAT export sales without proof of actual exportation.
Navigating Tax Penalties: Understanding the Supreme Court's Ruling on Late Filing and Surcharges
A clear guide to the Supreme Court's ruling on tax penalties, late filing, and surcharges under Philippine tax law.
Forest Charges and Tax Refunds: Jurisdiction and Prescription in Philippine Tax Law
A 2019 Supreme Court ruling clarifies that forest charges are internal revenue taxes, so refund claims must go to the CIR within two years.
Withholding Tax Obligations: When Final Withholding Tax Becomes Due
Learn when final withholding tax obligations arise under Philippine tax law, based on a Supreme Court ruling on interest payments.
Excise Tax on Cigarette Bundles: The Sin Tax Law and Packaging Rules
The Supreme Court ruled that excise tax applies to a 20-stick bundle as a whole, not to individual 5s or 10s pouches.
PAL Franchise Tax Exemption Survives Later Tax Laws: Supreme Court Ruling
The Supreme Court affirms PAL's excise tax exemption under PD 1590 despite RA 9334 and RA 9337 amendments.
Tax Evasion and Prescription: The Statute of Limitations in Philippine Tax Law
The Supreme Court clarifies when the three-year prescriptive period for tax assessment applies, and why fraud must be proven to trigger the ten-year rule.
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.
Exhaustion of Administrative Remedies and CTA Jurisdiction in Tax Disputes
The Supreme Court clarifies that the CTA cannot review the CIR's quasi-legislative interpretation of tax laws, and taxpayers must exhaust administrative remedies first.
VAT Refund Claims: Equitable Estoppel and Strict Interpretation of Tax Laws
Supreme Court ruling on VAT refund claims, transitional input tax credits, and the strict interpretation of tax laws in Fort Bonifacio Development Corporation v. CIR.
Strict 120+30 Day Rule for VAT Refund Claims in the Philippines
Learn the mandatory 120+30 day periods for VAT refund claims and why late judicial appeals are fatal under Philippine tax law.
Electronic Fund Transfers and Documentary Stamp Tax: Navigating Tax Laws in the Digital Age
The Supreme Court ruled that electronic fund transfer instructions are not bills of exchange subject to documentary stamp tax under Section 181.
VAT Refund Claims: Strict Deadlines and Invoice Requirements Under Philippine Tax Law
Learn how the Supreme Court's ruling in CIR v. Silicon Philippines clarifies the mandatory 120+30 day prescriptive periods for VAT refund claims and invoice requirements.
Directors' Bonuses and Withholding Tax: Clarifying Employee Status in Philippine Tax Law
Philippine Supreme Court ruling on directors' bonuses, withholding tax on compensation, and the definition of received a Letter of Authority in 1998 to examine its books for taxable year 1997. Followi
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.
Tax Refunds vs. Tax Liabilities: Understanding Set-Offs in Philippine Tax Law
The Supreme Court explains when a tax refund claim can be denied due to an underpayment—and why set-off rules apply differently in tax cases.
Withholding Agents and Tax Refunds: Balancing Rights and Responsibilities in Philippine Tax Law
When can a withholding agent claim a tax refund? The Supreme Court clarifies the rights and duties of withholding agents in refund claims.