cta_decision CTA Case No. 1127011270 2025-10-28

GE HEALTHCARE PHILIPPINES, INC., (formerly General Electric Philippines, Inc)., v. CIR v. COMMISSIONER OF INTERNAL REVENUE

CTA Fonn No.8 lllllllllllllll llllllllllllllllllllllllllll lllllllllll lllllll 23-000435-0040 REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY FIRST DIVISION CTA CASE N0.11270 GE HEALTHCARE PHILIPPINES, NOTICE OF DECISION INC., (formerly General Electric Philippines, Inc)., Petitioner, - versus- COMMISSIONER OF INTERNAL REVENUE, Respondent. To: OFFICE OF THE SOLICITOR GENERAL 134 Amorsolo Street, Legazpi Village Makati City ATTY. SYLVIA R. ALMA JOSE ATTY. AYESHA RANIA B. GUILING-MATANOG ATTY. MCLAIR D. GARCIA Bureau of Internal R evenue Room 703, Litigation Division, BIR National Office Buillding Sen. Miriam P. Defensor-Santiago Avenue Diliman, Quezon City CABRERA & COMPANY 28th Floor, AlA Tower (fonnerly Philamlife Tower) 8767 Paseo de Roxas 1226 Makati C ity GREETINGS: You are hereby notified by these presents that on October 28, 2025, a Decision was rendered in the above-entitled case, copy of which is attached hereto. Quezon City, Philippines, October 30, 2025. ... Atty. Maria ~a F. Chan-Te Executive berl<'6'fCourt III

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY FIRST DIVISION GE HEALTHCARE CTA CASE NO. 11270 PHILIPPINES, INC. (formerly General Electric Members: Philippines, Inc.), BACORRO-VILLENA, Acting Chairperson, and Petitioner) CUI-DAVID, JJ. -versus- COMMISSIONER OF Promulgated: INTERNAL REVENUE, OCT 28~025 )ol_:QAl PM Respondent. X- - - - - - - - - - - - - - - - - - - - - - - - - - ~ - - - - - - - - - - -X DECISION CUI-DAVID, J.: Before the Court is a Petition for Review filed on September 14, 2023, by petitioner GE Healthcare Philippines, � Inc. (formerly "General Electric Philippines, Inc .") ["Petitioner"] against respondent Commissioner of Internal Revenue ("CIR" or "Respondent"). Petitioner seeks the refund or issuance of a Tax Credit Certificate in the amount of P47,972,225.78, allegedly representing its erroneous payment of Final Withholding Tax (FWT) on royalties payable to GE Energy Switzerland GmbH (GE Switzerland), which was remitted to the Bureau of Internal Revenue (BIR) on September 15, 2021. THE PARTIES Petitioner is a domestic corporation duly organized and existing under Philippine laws, with registered office at 27th Floor Menarco Tower, 32nd Street, Bonifacio Global City, Fort Bonifacio, Taguig City. l It is a registered taxpayer with Tax v Identification Number (TIN) 000-121-766-00000 per BIR ' Dockot - Vol. 1., p. 6, P"Uion j& R.�i<w. I. P�rti.,, P"- I. 7, P<lilion foe R.�i<w. Ill . S"t<moot ofF"" Md Timeliness of the Petition, par. 3: Docket - Vol. II. pp. 633--652, Exhibits ��P- I,. and -- P-2...

DECISION CTA Case No. 11270 GE Healthcare Philippines, lnc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue Page 2 of23 X-------------------------------------------------------------------------------------------X Certificate of Registration issued on July 7, 1998.2 It is primarily engaged in general electrical business, performing and delivering technical services, and distribution of parts, among others.3 Respondent is vested by the National Internal Revenue Code (NIRC) with the authority to, among others, decide, approve, and grant applications for refund of erroneously or illegally collected national internal revenue taxes. The CIR may be served with summons and other court processes at the BIR National Office Building, Litigation Division, Room 703, Diliman, Quezon City.4 THE FACTS AND PROCEEDINGS BEFORE THE COURT On January 1, 2019, petitioner and GE Switzerland, a non-resident foreign corporation (NRFC) incorporated under the laws of Switzerland,5 entered into a Project Risk, Network & Technology License for Services6 (Agreement). In consideration of the rights granted for the use of licensed technology under the Agreement, petitioner agreed to pay fees to GE Switzerland for all services performed and sold, offered for sale, or otherwise used or disposed of using the licensed technology. On August 13, 2021, petitioner filed, via Electronic Filing and Payment Systems (eFPS), its Monthly Remittance Form of Final Income Taxes Withheld (BIR Form No. 0619-F) [FWT Return] for the month of July 2021 and paid the corresponding FWT in the adjusted amount of P22,946, 111.02. Petitioner v alleges that the said July 2021 FWT Return includes the FWT on royalties payable to GE Switzerland amounting to P46,295,334.82.7 Dock~t- Vol. I. p. 7. Petilion/or Rel�ielr. Ill. Stat..::m..::nt of Facts and Timclino:ss of the: Pc:tition. par. 4: Docket- Vol. IL pp. 653--655. Exhibit ��P-3"". Docket- Vol. I. p. 7. Petirionfor Rerie1r. Ill. Statement of Facts and Timeliness of the Petition. par. 3: Docket- Vol. II. pp. 633--652. Exhibits ��p-1�� and ��P-2"". Docket - Vol. I. p. ..J.I7-418. Joint St1jmlation of htcrs and Issues {JSFI ). I. Stipulation of facts. par. 1: Docket - Vol. L p. 447. Pre-Trial Oder dated Ma) 28. 2024. II L Admitted Facts and Stipulation of Facts. Docket- Vol. I. pp. 7-8. Petition for Revic\\�. pars. 5-6: Docket- Vol. II. pp. 656--659. 669 and 670. Exhibits ��p_ r ... P-5". and .. P-6--. respectively. E\.hibit P-8. BIR Records. pp. 5-28. In its Petitionfor RevieH�. petitioner alleges that it paid and remitted 'P46.295.33..J..82 pcrtaining to FWT on fO) alties payable to GE S\\ itzerland. as supported b) im oices issued by the latter. with details summarized as follo\\S: Income Recipient Invoice Im�oice Amount Im-oice Amount Tax Total :\umber (in ISO) (in PHP) Rate GE Enen:n s,,-itzerland GmbH 70037.:JSJJ..J. $..J..65..J..956.93 15% f33.831.171.41 GL Lnerg\ S\\�itzerland GmbH 2003245JI5 849.159.13 r225.540.&09.43 15% 6.171.486.88 Gl: !:nero\ Switzerland GmbH 7003745716 865.840.97 -l-1.143. J45.8S 6.797.776.53 $6.369.957.03 41.951.510.22 15~-o P~6,295,33~.82 r3o&.635.565.53

DECISION CTA Case No. 11270 GE Hea1thcare Philippines, lnc. (formerly General Electric Philippines, lnc.) v. Commissioner of Internal Revenue X-------------------------------------------------------------------------------------------X Thereafter, on September 13, 2021, petitioner filed via eFPS its FWT Retum8 for the month of August 2021, and paid the corresponding FWT on September 15, 2021,9 in the amount of !>51,271,825.70, a portion of which allegedly includes FWT paid and remitted on royalties payable to GE Switzerland totaling !>47,972,225.78. 10 On September 5, 2022, petitioner filed with the BIR International Tax Affairs Division an Application for Treaty Purposes (Relief from Philippine Income Tax on Royalties) (BIR Form No. 0901-R), 11 and a letter-request for confirmation of entitlement to the preferential tax rate under Article 12(2) of the Philippines-Switzerland Tax Treaty (RP-Switzerland Tax Treaty) to confirm the applicability of the 15% FWT on royalty payments to GE Switzerland for the use of its licensed technology. 12 On November 14, 2022, the BIR issued a Certificate of Entitlement to Treaty Benefit, 13 signed by Atty. Larry M. Barcelo, Assistant Commissioner, Legal Service, certifying and confirming that the royalty payments to GE Switzerland are subject to 15% FWT. On August 14, 2023, petitioner filed an Application for Refund ofExcess Withholding Tax in Accordance with the Double Taxation Convention {BIR Form No. 1914),14 and a letter- request15 for refund of erroneously paid FWT on royalties payable to GE Switzerland amounting to !>47,972,225.78, representing the alleged July 2021 FWT, which according to v petitioner was inadvertently reflected twice in both the July and August 2021 FWT Returns, and correspondingly paid twice on August 13,2021, and September 15,2021. !d at 683--685. Exhibit ��P-IT. !d. at 686. Exhibit "'P-12-J"". 10 In its Pelition for Ren�eu�. petitioner alleges that it erroneous!: paid and remitted 'P47.972.225.78 pertaining to the same FWT due on ro: a! ties payabk to GE S\\ itzc:rland. which \\CrC already paid for in the July 2021 FliT Return. with details summarized as J'ollm\s: Income Recipient lm�oice ln\'oicc Amount I m�oicc Amount Tax Total :\umber (in lSI)) (in PIIP) Rate GE Enerf;!\' Switzerland Gmbll 2003245214 S-L654.956.93 150/Q P35.056.539.35 GE Enerov S\\'itzerland GmbH '003'-ISJ 15 849.159.13 r?33. 71 o. ?62.36 6.395.0?7.04 GE Eneray Switzerland CimbH 2003245216 865.840.97 4?.633.513.6' 15%) 6.5?0.659.39 56.369.957.03 43.471.062.63 15% r~7,972,225.78 ?319.814.838.61 11 Docket- Vol. II. p. 688---689. Exhibit ��p.. J 3-1��. I~ Exhibit ��pM Ir. BIR Records. pp. 84-88. u Exhibit ��pMJ4"". BIR Records. pp. 92-94. 14 Docket- Vol. II. p. 690. Exhibits ��P-Is��. '' /d. at 691--697. Exhibits ��P-16".

DECISION CTA Case No. 11270 GE Hea1thcare Philippines, lnc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue X-------------------------------------------------------------------------------------------X Without awaiting the outcome of its administrative claim for refund, and with the two-year prescriptive period nearing its lapse, petitioner was compelled to elevate the matter to the Court via the present Petition for Review filed on September 14, 2023. 16 On October 16, 2023, Summons was issued and received by respondent on October 18, 2023.17 On November 16, 2023, respondent filed a Motion for Extension of Time to File Answer, 18 which was granted by the Court on November 28, 2023. 19 Within the extended period, respondent filed his Answer (Re: Petition for Review dated 14 September 2023) on December 15, 2023.20 On December 18, 2023, respondent submitted to the Court the BIR Records of the case, consisting of one folder with 94 pages, through his Compliance.2l Thereafter, the Pre-Trial Conference was conducted on March 13, 2024. 22 Prior thereto, the Pre-Trial Brief(ofPetitioner General Electric Philippines, Inc.j23 and respondent's Pre-Trial Briej24 were respectively submitted on March 8, 2024. On April 2, 2024, the parties filed their Joint Stipulation of Facts and Issues,25 which was approved by the Court in a Resolution dated April 25, 2024,26 thereby terminating the pre- trial. The Pre-Trial Order was issued on May 28, 2024. 27 During trial, petitioner presented both testimonial and documentary evidence. It offered the testimonies of the following witnesses: (1) Mr. Nelson V. Soriano (Mr. Soriano),2s Tax Executive Director of Isla Lipana & Co.; (2) Mr. Armando V. Dayag, Jr. (Mr. Dayag),29 petitioner's former Tax Operations 16 Docket- Vol. L pp. 6-25. 17 /d. at 35-J.. IS fd at 357-360. 19 ld at 36.2. Resolution dated September 30. 2022. " fd at364-372. 21 /d. at 374-376. Compliance. ~' !d. at 380-382. T\otice of Pre-Trial Conkrence dakd January 17. 2024. " !d at 392--106. ::..1 !d. at 384-387. ~ 5 !d at 417--424. 26 /d at 428. 27 !d. at 440--453. ~s Docket- Vol. II. pp. 463--480. E:\hibit �P-2o��..-1 mended Judicial .-1(/ldorit of .\Jr..\dson I�. .)'oriano: 61 1-61 7. Minutes of the hearing held on. and Order dated. June 5. 2024. ~0 Docket- VoL I. pp. 272-280. E:\hihit ��P-22"". Judicial .�lf(idavit q(.-lrmundo /'. Doyag, Jr.: Docket- VoL II. pp. 611-617. :'vlinutes of the hearing held on. and Order dated. June 5. 2024.

DECISION CTA Case No. 11270 GE Healthcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue Page 5 of23 X-------------------------------------------------------------------------------------------X Manager; and (3) Mr. Jaysonn A. Javier,3� petitioner's Lead Controllership Analyst. On June 18, 2024, petitioner filed a Formal Offer of Evidence (By Petitioner General Electric Philippines, Inc.J,3 1 to which respondent filed his Comment (on Petitioner's Formal Offer of Evidence) on June 24, 2024.32 In turn, on July 18, 2024, petitioner filed a Manifestation with Comment/ Opposition [Re: Respondent's Comment (on Petitioner's Formal Offer ofEvidence) dated 20 June 2024].33 On September 12, 2024, acting on the Formal Offer of Evidence (By Petitioner General Electric Philippines, Inc.), the Court admitted all of petitioner's offered exhibits.34 In his Comment (on Petitioner's Formal Offer of Evidence), respondent manifested that he would no longer present evidence, after confirmation that a report had yet to be issued by the revenue officer who handled the case.35 On October 17,2024, petitioner's Memorandum (ofGeneral Electric Philippines, Inc.j36 and respondent's Memorandum3 7 were respectively submitted. The present case was deemed submitted for decision on November 7, 2024.38 On August 27, 2025, petitioner filed a Manifestation with Motion to Adopt Amended Corporate Name, requesting the Court to adopt and reflect its amended corporate name, from "General Electric Philippines, Inc." to "GE Healthcare Philippines, Inc.," in all orders, notices, and other court processes. The Court v granted the same in its Resolution dated September 25, 2025. 10 Docket- Vol. L pp. 295-300, E:xhihit ��P-21". Judicial A(lidarit of.Jaysonn.-1. Jarier: Docket- Vol. IL pp. 6\1- 617. Minut~s of the hearing held on. and Orderdat..::d. June 5. 202-1-. -' 1 Docket- Vol. II. pp. 624--632. " !d. at 713-717. ~-' !d at 722-728. ,_. /d at 732-733. Resolution dat~d September 12.202-1-. -'~ !d. at 715. Comment (on Petitionr!r 's Formal Offer f?{Ln'dence). par. I0. "' !d. at?-17-768. �17 !d. at 734-743. '~ !d. at 1395. Notice of Resolution dated Nc)\'cmber 7. 202--J..

DECISION CTA Case No. 11270 GE Healthcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue Page 6 of23 X-------------------------------------------------------------------------------------------X THE ISSUE As stipulated by the parties, the sole issue for the Court's resolution is: WHETHER PETITIONER IS ENTITLED TO A TAX REFUND/CREDIT CERTIFICATE AMOUNTING TO 1."47,972,225.78 REPRESENTING ITS ERRONEOUS PAYMENT OF FINAL WITHHOLDING TAX (FWT) ON THE ROYALTIES PAYABLE TO GE SWITZERLAND PAID TO THE BIR ON 15 SEPTEMBER 2021.39 Petitioner's arguments: In its Petition for Review and Memorandum, petitioner contends that: 1. It is registered with the BIR as a taxpayer; 2. The royalties payable to GE Switzerland, an NRFC, are subject to the preferential tax rate of 15% FWT pursuant to the RP-Switzerland Tax Treaty; 3. It erroneously paid the corresponding FWT on royalties to GE Switzerland twice for the month of July 2021; 4. It was able to show sufficient proof of payment, and there was actual collection and receipt by the government of the tax sought to be recovered; 5. Both the administrative and judicial claims for tax refund were filed within the two-year prescriptive period; and 6. The erroneously paid FWT on royalty payment should be refunded following the principle of solutio indebiti. Respondent's counter-arguments: In his Answer and Memorandum, respondent contends that petitioner failed to exhaust administrative remedies before elevating the case to this Court, as petitioner admitted that it did not await the outcome of its refund application but immediately resorted to filing the present Petition for Review. He further argues that the principle of solutio indebiti is not applicable because the royalty tax was not erroneously paid, as y petitioner was merely complying with its tax liability and paying the amount due to the government. 39 Docket- Vol. I. p. 4-47. Pre-Trial Ord..::r. IV. Issuc/s to he Tried or Rcsoln::d.

DECISION CTA Case No. 11270 GE Hea1thcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue x-------------------------------------------------------------------------------------------x As derived from the foregoing provisions and settled jurisprudence, the requirements for the refund of erroneously or illegally paid taxes are as follows: (1) A written claim for refund or tax credit must be filed with the CIR within two years from the date of payment of the tax or penalty;40 (2) In case of denial or inaction by the CIR within the said period, the petition for refund must be filed with the CTA within 30 days from receipt of the denial and within the said two-year period from the date of payment of the tax or penalty, regardless of any supervening cause;4t (3) The claim for refund must be a categorical demand for reimbursement;42 and (4) There must be proof of payment of the erroneously or illegally collected taxes43 First and second requirements: Petitioner timely filed its administrative and judicial claims. Sections 204(C) and 229 ofthe NIRC of 1997, as amended, explicitly require that a claimant must first file an administrative claim for refund or tax credit with the BIR within two years from the date of payment of the tax. Only then may a judicial claim be pursued. Under prevailing law, both administrative and judicial claims must be filed within the same two-year reglementary period. The Supreme Court consistently held that the "[t]imeliness v of filing the claim is mandatory and jurisdictional. The [Court of Tax Appeals] cannot take cognizance of a judicial claim for refund filed either prematurely or out of time." 44 Commissioner of!merna! Revenue ,._ I 'ictorias .\Iiiling Co.. Inc .. eta!.. G.R. No. L-241 08. January 3. 1968 lPcr J. Bengzon. En Bane]: See also Commissioner (?(Internal Re,�enue r. Acosta. G.R. No. 154068. August 3. 2007 [Per J. Quisumbing. Second Division]. Gihhs. era/. v. Collector a( Internal Ren!l11!1! er..-/!.. G.R. No. LMI3..J.53. fcbrual"\ 29. 1960. 107 PhiL 232 (1960) [Per J. Barrera. /:."n Bane[: S!.!e also Commissioner o.fInfernal Revenue r . .-!costa. (J.R. No. 154068. August 3. 2007 [Per .1. Quisumbing. Second DiYision[. Bermejo v. The Co!/ectur qf1nternal Re\�enue. G.R. No. L-3029. July 25. 1950. 87 Phil. 96 ( 1950) lPer J. Bengzon. En Bane[: Sec also Commissioner of Internal Rewnue v. Acosta. Ci.R. No. 154068. August 3. 2007 fPcr J. Quisumbing. Second DiYision]. 43 Aguilar\'. Commissioner of!merna/ Revenue. CJ\MG.R. SPM 16432. March 30. 1990. Commissioner of /merna/ Revenue r. Carrier Air Conditioning Philippines, Inc .. G.R. No. 226592. Jul) 27. 2021 [Per J. Leon en. Ln Bane[: See also Commissioner r?flntemal Rt:venue v. San .lfiguel Corporation, et seq.. G.R. Nos. 180740 & 180910. i\ovember II. 2019 {Per .1. Hernando. Second Division] citing Commissioner of Internal

DECISION CTA Case No. 11270 GE Healthcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue Page 9 of23 X-------------------------------------------------------------------------------------------X It is also worth stressing that, as for the judicial claim, Section 229 explicitly provides that it be filed within two years from the date of payment of the tax "regardless of any supervening cause that may arise after payment."4s A perusal of the records reveals that petitioner filed a written claim with the CIR, as evidenced by its duly accomplished Application for Refund of Excess Withholding Tax in Accordance with the Double Taxation Convention (BIR Form No. 1914f6 and a letter-request for refund dated August 14, 2023. 47 The relevant dates in relation to the two-year prescriptive period are summarized below: Event Date I Filing of FWT Return for August 2021 II September 13, 2021481 II Payment of FWT II September 15, 2021491 I Filing of Administrative Claim II August 14, 2023�0 I II Filing of Judicial Claim II September 14, 202351 I I End of Two-Year Prescriptive Period II September 15, 2023 I Petitioner paid the subject FWT amounting to '1'47,972,225.78 on September 15, 2021. Thus, it had two years from September 15, 2021, or until September 15, 2023, to file both administrative and judicial claims. Considering that the administrative claim was filed on August 14, 2023, and the Petition for Review was subsequently filed on September 14, 2023,52 both claims were timely filed within the two-year prescriptive period under Sections 204(C) and 229 of the NIRC of 1997, as amended. Respondent's assertion that the case should be dismissed v for failure to exhaust administrative remedies is untenable. Revenue\'. l'nited Cadi:: Sugar Fanm:rs .�lssociation .\!ulri-Purpose Cuuperatll'e. G.R. No. 209776. D~cemhc:r 7. 2016. 802 Phil. 636. 645 (2016) [Per J. Brion. Second Division]. -t~ Commissioner ofInternal Ren:nue \'.San .\l(euel Corporation. et seq. G.R. Nos. 180740 & \80910. November I L 2019 rr.:r J. Hernando. Second DiYision]. 4r� Docket- Vol. II. p. 690. Exhibits "P-15"'. 47 !d. at691--697. Exhibits .. P-16". 48 /d. at 683--685. Exhibit "P-IT. 49 /d. at 686. Exhibit "P-12-1". -'0 !d. at 690--697. Exhibits ��P-15" and "P-16". ~ 1 Docket- VoL I. pp. 6-25. ~2 !d.

DECISION CTA Case No. 11270 GE Healthcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue x-------------------------------------------------------------------------------------------x As held in Commissioner of Internal Revenue v. Philippine Bank of Communications,53 the independence of a judicial claim for refund or tax credit from its administrative counterpart is implied in the NIRC of 1997, as amended, which allows the filing of both claims contemporaneously within the two-year prescriptive period. Notably, Section 229 does not require prior action by the CIR before a judicial claim may be initiated; it merely requires that a claim be filed with the CIR. In fine, petitioner has satisfied the first and second requirements for a valid claim for refund or tax credit. Consequently, the Court affirms its jurisdiction over the instant case. Third requirement: Petitioner's claim for refund contains a categorical demand for reimbursement. As previously discussed, petitioner filed on August 14, 2023 its letter-request for refund of erroneously paid FWT on royalties amounting to ~47,972,225.78. 54 The letter-request clearly and unequivocally demands reimbursement, as shown in the following excerpt: On behalf of our client, General Electric Philippines, Inc. (hereinafter referred to as "GEPI" or the "Company"), we respectfully submit this letter request for tax refund of erroneously paid Final Withholding Tax ("FWT") on royalties on 15 September 2021 to the Bureau of Internal Revenue ("BIR") amounting to PHP 47,972,225.78 relative to the royalties payable to GE Energy Switzerland ("GE Switzerland"). Pursuant to Article 12(2) of the Philippines- Switzerland Tax Treaty ("Tax Treaty"), the royalties were subjected to a reduced FWT rate of 15 percent (15%). In view of the foregoing, we respectfully submit this letter request for the cash refund of the erroneously paid FWT by GEPI amounting to PHP 47,972,225.78. This statement satisfies the third requirement, as it constitutes a clear and direct demand for the refund of the amount erroneously paid. '-' G.R. No. 2113-1-8. fcbruar: 23.2022 [Per J. Ilernando. Second Divi~ionJ. 54 Docket- Vol. II. pp. 691-1>97. F,,hibits ""P-16��.

DECISION CTA Case No. 11270 GE Healthcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue X-------------------------------------------------------------------------------------------X Fourth requirement: Petitioner failed to prove that there was an erroneous or illegal FWT collection by the government. The fourth requirement necessitates that there must be proof of payment of the erroneously or illegally collected taxes. Section 229 of the NIRC of 1997, as amended, allows the recovery of taxes erroneously or illegally collected. An "erroneous or illegal tax" is defined as one levied without statutory authority, or upon property not subject to taxation, or by some officer having no authority to levy the tax, or one which is some other similar respect is illegal.55 In other words, what can be refunded or credited is a tax that is erroneously, illegally, excessively, or in any manner wrongfully collected. In short, there must be a wrongful payment because what is paid, or part of it, is not legally due.56 Thus, to sustain a refund claim, the taxpayer must show not only the timely filing of administrative and judicial claims but also that the FWT paid was erroneously, illegally, or wrongfully collected. In the present case, the alleged erroneous tax collection pertains to the 15% FWT withheld and paid on royalties payable to GE Switzerland for July 2021, which were mistakenly included in the computation and payment of petitioner's FWT for August 2021. As a general rule, NRFCs such as GE Switzerland are subject to a 25% income tax on royalties derived from Philippine sources, effective January 1, 2021, pursuant to Section 28 (B) (1) of the NIRC of 1997, as amended by Republic Act (RA) No. 11534,57 which provides: SEC. 28. Rates ofIncome Tax on Foreign Corporations. - (B) Tax on Nonresident Foreign Corporation. - Commissioner o(/nt!'rna! Revenue\'. Pi!ipinas Shell Petroleum Corporarion. G.R.1\o. 188497. /\pril25. 2012 [Per J. Villarama. Jr.. J.j citing th~ definition prm idcd in l3lad;_�s Law Dictionary. 5111 Edition. p. 486. Commissioner f?( Internal Revenue\'. San Roque Pol\'er Corporarion. et W!tj.. G.R. 1\:os. 187485. 196113 & 197156. Februar~ 12.2013 [Per J. Carpio. En Bane] 57 Otherwise kn0\\11 as ""Corporate Reco\'ery and Tax lncentiYes for Enterprises AcC or "CREATE".

DECISION CTA Case No. 11270 GE Healthcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue Page 12 of23 x-------------------------------------------------------------------------------------------x (1) In General. -Except as otherwise provided in this Code, a foreign corporation not engaged in trade or business in the Philippines, effective January 1, 2021, shall pay a tax equal to twenty-five percent (25%) of the gross income received during each taxable year from all sources within the Philippines, such as interests, dividends, rents, royalties, salaries, premiums (except reinsurance premiums), annuities, emoluments or other fixed or determinable annual, periodic or casual gains, profits and income, and capital gains, except capital gains subject to tax under subparagraph S(c). However, the foregoing tax rate may be reduced to the extent required by any treaty obligation binding upon the Philippine government, as provided in Section 32 (B) (5) of the NIRC of 1997, as amended: SEC. 32. Gross Income- (A) General Definition. - Except when otherwise provided in this Title, gross income means all income derived from whatever source, including (but not limited to) the following items: (6) Royalties; (B) Exclusions from Gross Income.- The following items shall not be included in gross income and shall be exempt from taxation under this Title: (5) Income Exempt under Treaty. -Income of any kind, to the extent required by any treaty obligation binding upon the Government of the Philippines. In this regard, Article 12 of the RP-Switzerland Tax Treaty58 provides: ARTICLE 12 Royalties 1. Royalties arising in a Contracting State and paid to a � . . . resident of the other Contracting State may be taxed in that other State. ' 8 Convention Bet\\t:en the Republic of the Philippines and the Swiss Conkderation. RP- Smss Confederation. June 24. 1998.

DECISION CTA Case No. 11270 GE Healthcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue X-------------------------------------------------------------------------------------------X 2. However, the royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but the tax so charged shall not exceed 15 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematographic films and films and tapes for television or radio broadcasting, any patent, trademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. (Emphasis supplied) Thus, royalties arising in the Philippines and paid to a resident of Switzerland may be taxed in the Philippines, but only up to 15% of the gross amount of royalties, in accordance with the RP-Switzerland Tax Treaty. To determine whether GE Switzerland qualifies as a "resident of a Contracting State," Article 4 (paragraph 1) of the RP-Switzerland Tax Treaty provides: "Article 4 RESIDENT 1. For the purposes of this Convention, the term 'resident of a Contracting State' means any person who, under the laws of the State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature." Here, petitioner has sufficiently established that GE Switzerland is a resident of Switzerland based on the following supporting documents: 1. Apostilled Articles of Association dated July 17, 20 15;59 2. Apostilled Certificate of Residence dated August 17, 2023, issued by the Swiss Tax Authority;60 and 3. Certificate of Non-Registration of Company dated July 4, 2023, issued by the Securities and Exchange Commission61 In addition, the Certificate ofEntitlement to Treaty Benejif62 issued by the BIR on November 12, 2022 confirms that the 9 Docket- Vol. II. pp. 656--659. Exhibits .. P-4". -' 00 fd at 669. Exhibits .. p_s��. 61 Jd. at 670. Exhibits ��r-6��. ll: E:\hibit ��P-1-1-��. BIR Records. pp. 92-94.

DECISION CTA Case No. 11270 GE Healthcare Philippines, lnc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue Page 14 of23 x-------------------------------------------------------------------------------------------x royalties ansmg from petitioner's Agreement with GE Switzerland qualify for the 15% preferential FWT rate pursuant to the RP-Switzerland Tax Treaty. Thus, the subject royalties were correctly subjected to 15% FWT. Having established that the 15% preferential tax rate on royalties under the RP-Switzerland Tax Treaty was properly applied, petitioner must now prove that it actually withheld and remitted the 15% FWT twice, resulting in the alleged erroneous payment of taxes amounting to f>47,972,225.78. To recapitulate, petitioner claims that it remitted and paid to the BIR the 15% FWT on royalties payable to GE Switzerland for July 2021 on two occasions: first on August 13, 2021, and again on September 15, 2021. If true, the second remittance would constitute an erroneous payment, as the tax due had already been settled.63 To support its claim, petitioner presented the following documentary evidence: 1. BIR Filing Reference No. 442100043217780 with FWT Return for July 2021 ;64 2. eFPS Payment Details for the tax period July 31, 2021 ;65 3. Alphalist ofPayees for July 2021 ;66 4. BIR Filing Reference No. 442100043694747 with FWT Return for August 2021 ;67 5. eFPS Payment Details for the tax period August 31, 2021 ;68 6. Alphalist of Payees for August 2021 ;69 7. Invoices issued by GE Switzerland;7o 8. Letter request for the issuance of Delinquency Verification Certificate dated April 16, 2024, and received by BIR Large Taxpayers Service on even date;71 9. Letter request for issuance of internal revenue payments dated April 17, 2024;72 10. Delinquency Verification Certification issued on April30, 2024;73 and 11. Certification of Tax Payment issued on May 28, 2024.74 63 Docket- Vol. L p. I0. Petition for Rcvic\r. par. 12. r'4 Docket- Vol. II. pp. 677---fJ79. Exhibit ��P-11 --. 6" ld at 680--681. Exhibit ��P-11-1'". 66 !d at 682. Exhibit ��P-11-T. 67 ld at 683--685. Exhibit ��P-12"". "s !d. at 686. Exhibit .. P-12-1 ... Ml /J. at 687. Exhibit ��P-12-T. 70 /d. at 674--670. Exhibits .. P-10..... P-10-1 ... and ��P-10-T. 71 /d. at 700-701.1->.hibit --P-18... 7~ !d. at 702-203. E:-.hibit .. P-18-1 ... 73 /d. at 706. Exhibit --r-19... 74 Jd. at 797. Exhibit --P-19-1 ...

DECISION CTA Case No. 11270 GE Healthcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue x-------------------------------------------------------------------------------------------x Upon review, the Court finds that petitioner remitted f>22,946,111.02 and t>51,271,825.70, as reflected in its FWT Returns for July and August 2021, respectively. Further examination of the Alphalist ofPayees for August 2021 shows that the royalties and corresponding FWT due to GE Switzerland amounting to f>47,972,225.78 were, in fact, included in the amount remitted and paid to BIR, totaling f>51 ,271 ,825. 70. 7s However, the same cannot be conclusively said for the FWT due amounting to f>46,295,334.82 pertaining to royalties payable to GE Switzerland for July 2021. It bears stressing that the Alphalist ofPayees for July 2021, which can be found in the BIR Records, shows royalty payments of 'P34,556,514.88, 'P41,143,245.88, and 'P41,951,510.22 to GE Switzerland, with corresponding FWT of 'P5,183,477.23, 'P6,171,486.88, and 'P6,292,726.53, or in the aggregate amount of 'P17,647,690.64. On the other hand, the Alphalist ofPayees76 for the same period offered by petitioner reflects FWT amounts of 'P33,831, 121.41, 'P6,171,486.88, and 'P6,292,726.53, as well as an apparent deduction or negative amount of 'P28,647,664.18, resulting m the same net aggregate amount of 'P17 ,647,690.64.77 ~ 75 An c:-..:cerpt of the n:k\�ant details of the .�llplwlist o/"Puyees for August 2021 FliT Retum is sho,,n below with the ~.:mphasis supp!i~d on tile three transactions \Vith CJE S\\ itzerland totaling to f"-l-7.972.225.79 and noting a rounding otT Jift(:rencc of 0.0 I: GE POWL.::R SOLU I" IONS MAI.A YSJA SDN BlllJ i\UL'-21 \.1/(230 0.25 5.-127.511.8-1 ] __156.877_96 GE POWER SOLUTIONS :vlALA YSIA SD\1 BIIIJ GE PO\\.'f:R SOLUTIONS MALAYSIA SON BHD Aul!-11 WC230 0 25 3_..!88.967...17 87::.241.87 GE E:\ERGY SWITZERL:\:\0 G\IRH CH GE E\"ERGY SWITZERLA:\D G'IBII CH Altl'-'"~1 WC'"~30 0 25 1.909.362 70 -177.3-l0.68 CE E'ERGY S\\'ITZERL\:\0 C\IHII Cll JU>C DWCLLC S:l.J-957 Auu- 1 1 ' \VC250 O.b :n:uto,2&2 36 35,056,539.35 Au!.!-21 li.IS .J-2.6.>:;_5!J.6' 6,395,027.0-l. WC'"~50 Au!.! 21 6 WC::'~O 0.15 -L".-171.06~_63 6,:'20,659.39 Auu-'1 WC':"O 0 25 :2..>72.557.60 593.1.'9 -10 ;\ue-21 33.>.0 I 3..:?JX.2 51.27UC5.7 "' Dockd- VoL II. p. 682. Exhibit ""P-11-T. An excerpt of the rcleYant details of the .-1/plwlist (~/"Payees for Jul) 2021 FJI T Rerurn is shO\\�n belm\ with emphasis supplied on the negatiYe amount offJ28.6..J.7.64-l-.18 pertaining to a transaction \Vith Gr: S\\itzcrland: PTGEOJ PS JD Jul-J I we no 20 ())~ 10.;54-17.81 158861.95 PTGEOI PS 10 Jul-11 800815 85 10010.' 96 Jul- J I 21 \\'C1.'0 0.25 2 I96608.5-1 5..\9))2.13 GENERAL ELlCTR1C ll\TERNATIONAL 1:--.IC MY Jul 21 -19098-129-t:"'i -28647644.18 JuP I 11 WC130 0.15 J07-186.87 GE E:\ERGY SWITZERL\\"0 G:\IBH CH Jul 21 -I..\38J2.1.91 51871.71 GE INTERNATIONAl. 1:--.IC .lul-21 1.' WC150 0.15 II 09555.98 GUJ PS MY Jni-21 16958.11 USES PAYROLL and OTI Jl:.R Jul-21 " WC30 0.25 118.2.'79.53 -12.:<9.5.' Ho1Hien I Jua Enl!ineerinu Co Ltd Jul-21 27J8885J3 19559-1.88 J lo1Hicn !-lua En,ineerinu Co Ltd Jul 21 1J \\'C230 0.15 .'2-12713 17 689721 J.< INP l:nuineerin" and Scr\�iccs Uf...: Ltd Jul 21 1666-156.97 810678 19 1NP Deutschl<md GmbH Sl9167 Jul 21 """"_,0 WC230 0 15 1593298.8 66661..\ '-1 INP Deutschland GmbH 519167 Jul 21 0 15 2255-10809 -1 6..\8324 70 CE E:\ERGY SWITZERL\:\0 (;:\IBH CH Jul-21 wcno 0 25 411432..\5.88 33831121..1-1 GE E'\ERGY SWITZERL\\"0 G:\IBII Cl1 .lui 21 0.25 41951510.22 6171486.88 GE E\"I�:RGY SWITZERL\:\0 G\IBH Cll JL!i 21 WC130 0.25 116357.45 6292726.53 Jul 21 II an 7.honc> WC230 2420 -.13 5 6 5 8 9 ..>6 Han Zhon" -17..\371.26 605.11 Knn LJeok Rae we no �'I weno ().J5 --1.'592 82 �'' WC250 0.15 -'�' WC250 0.1 J .'-I WC250 0 15 ~5 wr.>.>o () 25 Y1 Wl330 0 25 _,7 \\'1330 O.J5 Jul-21 1.'8S-I-1952 ) 129-16111.02

DECISION CTA Case No. 11270 GE Healthcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue X-------------------------------------------------------------------------------------------X Petitioner, however, failed to explain the nature and basis of the P28,647,664.18 adjustment pertaining to GE Switzerland that would justify its deductibility. It alleges that it paid and remitted the amount of P22,946, 111.02, which was "after adjustment"78 but did not elaborate on the computation or justification for the deduction. Furthermore, in his testimony,79 Mr. Soriano, petitioner's witness, simply presented a breakdown of the total FWT filed and paid on August 13, 2021, without providing any explanation regarding the "Credit Note" in the amount of P28,647 ,664.18, which was deducted from the total FWT withheld from GE Switzerland, as follows: 12. Q: Relatively, in your answer to Question No. 7, you likewise mentioned that petitioner withheld 15% FWT amounting to I'46,295,334.82 on the royalties payable to GE Switzerland for July 2021, how was this amount arrived at? A: Based on the documents provided to us by the Petitioner, for the month of July 2021, Petitioner included the three royalty invoices (i.e., invoice nos. 2003245214, 2003245215, and 2003245216) received from GE Switzerland and subjected the gross invoice amount to 15% FWT. These were included in the total FWT which was filed and paid on 13 August 2021 in the total amount of '1'22,946, 111.02, net of deductions and other adjustments, as follows: INCOME INVOICE INVOICE INVOICE TAX RATE TOTAL I' RECIPIENT NUMBER AMOUNT AMOUNT (IN PHP)! liN USDl liN PHPl GE Energy I Swilzertand 2003245214 4,654,956.93 225,540,809.43 15% I GmbH ! GE Energy 2003245215 849,159.13 41 '143,245.88 15% Swrtzertand 33,831,121.~ GmbH 2003245216 865,840.97 41,951,510.22 15% GE Energy I Switzertand I GmbH i 6,171,486 ~ 6,292,726 \ Sub Total 6,369,957.03 308,635,565.53 46,295,334.1 Less: Credit Note 28,847,844. 3,941,741.73 190,984,284.62 15% ' TOTAL 17,647,690.~ Add: All Other Income 437,418.29 21 '193,681.51 25% l 5,298,420 Reci ients 22,946,111.~ GRAND TOTAL 78 Docket- Vol. L p. 9. Petition for Re,�ie�r. par. 9. ~ 70 Docket- Vol. II. pp. 463--480. Exhibit ""P-20"". Amended Judicial A.ffidarit ofJ!r. .\"e/son I�. Soriano.

DECISION CTA Case No. 11270 GE Hea1thcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue X-------------------------------------------------------------------------------------------X Given this lack of explanation, the Court cannot presume that the FWT due of !'46,295,334.82, corresponding to the royalties payable to GE Switzerland, was fully paid and remitted in relation to the July 2021 FWT Return and eFPS Payment Details which reflected payment of only P22,946,111.02.so Also, petitioner failed to prove that no royalty fees were due to GE Switzerland on a monthly basis. Consequently, the Court cannot ascertain whether there were other royalty payments for July 2021 covered by a different set of invoices separate and distinct from those invoices already presented before the Court. Indeed, it remains possible that the FWT remitted for July and August 2021 represented taxes actually due. Verily, since the supposed remittance and payment of !'46,295,334.82 was not convincingly established, the alleged double payment invoked by petitioner is purely speculative. This finding prompts the Court to thoroughly scrutinize whether the alleged FWT payment was indeed erroneous or illegal, to determine compliance with the fourth requirement for refund. As earlier noted, petitioner's claim is premised on the alleged double payment of FWT due, and it presented Invoice Nos. 2003245214, 2003245215, and 2003245216, which were issued by GE Switzerland, with details summarized as follows: Invoice Invoice Date Invoice FWTat 15% Net Payable Number Amount (in USD) June 16, 2021 (in USD) 200324521481 June 16, 2021 $698,243.54 $3,956,713.39 200324521582 June 16, 2021 $4,654,956.93 127,373.87 721,785.26 200324521683 849,159.13 129,876.15 735,964.82 865,840.97 $955,493.55 $5,414,463.48 $6,369,957.03 The Court also noted a variance oft'1,676,890.96 between the amounts of FWT due on royalties payable to GE Switzerland as reported in the July and August 2021 FWT Returns, computed as: w See Line 19 or July 2021 FliT Return. E\hibit ��P-1\"". 81 Docket- Vol. II. p. 67.:1-. E:-.:hibit ��P-10��. 8~ ld at 675. Exhibit "P-10-1"". ~3 !d. at 676. F->.:hibit ��P-10-T.

DECISION CTA Case No. 11270 GE Hea1thcare Philippines, Inc. (formerly General Electric Philippines, lnc.) v. Commissioner of Internal Revenue X-------------------------------------------------------------------------------------------X July 2021 FWT Return Reported FWT Due August 2021 FWT Return 1"46,295,334.82 Variance 47,972,225.78 (1'1,676,890.961 In his testimony, Mr. Dayag, petitioner's former Tax Operations Manager, explained that the discrepancy was due to differences in the foreign exchange conversion rates used internally by petitioner, viz.: 15. Q: Mr. Dayag, in relation to your answer in Question No. 14, you mentioned that "The Alphalist of Payees for both 31 July 2021 and 31 August 2021 would show that GE Switzerland is the recipient of the same royalties in the aggregate gross amount of P308,635,565.53 and P319,814,838.61, respectively. The FWT due on the said amounts are 1'46,295,334.82 and 1'47,972,225.78." Why is there a difference in the amount of royalties payable to GE Switzerland for July 2021 and the corresponding FWT due? A: The variance in the amount of royalties payable to GE Switzerland and the corresponding FWT was due to the foreign exchange conversion rate of the US dollar used by the Petitioner internally (i.e., 1'48.45175 and 1'50.20675). (Emphasis supplied) Moreover, during the hearing on June 5, 2024, Mr. Dayag clarified how the alleged erroneous payment was discovered:84 JUSTICE DAVID Were you the one who discovered the mistake and the error? MR. DAYAG Yes, your Honors. JUSTICE DAVID How did you find out that there was an erroneous payment of the royalties? s.. TSN. June 5. 2024. Mr. Armando'"� Da) ag. Jr.. pp. 17-19.

DECISION CTA Case No. 11270 GE Healthcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue Page 20 of23 X-------------------------------------------------------------------------------------------X happened within the transition. They missed that it has already been filed in July. And, part of our control is to check for all series invoices filed during the period whether it has already been filed by different preparer. But it just so happened that it's in a different period, August. So, the checking was done nearly on the period August, we failed to refer back to the prior Return. JUSTICE DAVID Okay, thank you for the clarification Mr. Dayag. You are now excused, you can go back to your seat. MR. DAYAG Thank you, your Honors. (Emphasis supplied) Despite these explanations, the Court remains unconvinced that the same set of invoices was erroneously subjected to withholding twice under both the July and August 2021 FWT Returns. Petitioner failed to present competent corroborating evidence to establish that the entries reflected in both returns pertained to identical transactions with GE Switzerland. Notably, the Court was also unable to verify whether there were other royalty transactions between petitioner and GE Switzerland under their Agreement for August 2021. Petitioner likewise failed to submit supporting documents, such as schedules of royalty payments, proof of actual payment transfer to GE Switzerland, or other relevant tax filings, including its Quarterly Remittance Return ofFinal Income Taxes Withheld (BIR Form No. 1601-FQ). In the absence of these documents, the Court cannot ascertain whether the royalties for July 2021 were indeed paid twice, or whether separate royalties were due for August 2021. It is basic in the rule of evidence that bare allegations, unsubstantiated by evidence, are not equivalent to proof. Simply put, mere allegations are not evidence.ss Based on the foregoing disquisition, petitioner failed to present clear and convincing proof that there was an erroneous 2~0774. F~rstv I olD Seat Plulippuin Cmpouilionl I clmw eta/.(, R No '' \1mch 3 2021 [Per .I Gacrlan Division 1.

DECISION CTA Case No. 11270 GE Healthcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue x-------------------------------------------------------------------------------------------x payment of FWT amounting to 1'47,972,225.78. Accordingly, petitioner did not satisfy the fourth requirement for a refund of taxes erroneously or illegally collected under Sections 204 and 209 of the NIRC of 1997, as amended. As a final note, while our legal system adheres to the long- standing principle that no one shall unjustly enrich oneself at the expense of another, which equally applies not only to individuals but also to the government,86 and that tax refunds are based on the principle of quasi-contract or solutio indebiti,87 the burden of proof to establish entitlement to refund is on the claimant taxpayer. It must be emphasized that actions for tax refund or credit, as in the present case, are in the nature of tax exemptions. As such, they are regarded as a derogation of sovereign authority and construed strictissimi juris against the person or entity claiming the refund.ss Since taxes are the lifeblood of the government, tax laws must be faithfully and strictly implemented, as they are not intended to be liberally construed.89 Hence, an applicant for a claim for refund or tax credit must not only prove entitlement to the claim but also compliance with all the documentary and evidentiary requirements. go WHEREFORE, in light of the foregoing considerations, the present Petition for Review is DENIED for lack of merit. SO ORDERED. ~iln~ LANEE S. CUI~AVID Associate Justice sc Civil Code. Arts. 2142 and 2154: Sec Fi/inn:st Derelopment Corporulion v. ('ommissioner of Internal Revenue, G.R. :.Jo.\46941. August 9. 2007lPcr J. Nachura. Third Oi\ ision]: Sec also Commissioner a( Internal Re,�emu: ;�. Fireman's Fund Insurance Co.. Ci.R. No. L-3064-L \!larch 9. 1987. 232 Phil 292-30 I [Per J. Paras. Second Division]. Commissioner of/merna/ Rerenue ,._ .-lcesite rPhilljJfJines) Hotel Corporation. G.R. T\o. 147295. February 16. 2007[Per J. Velasco. Jr.. Second DiYisionJ. ss Commissioner o("lnrernal Re1�enue r. S.C. Johnson & .)'on Inc.. eta!.. Ci.R. 1\o. 127105. June 25. 1999]Per .1. Cionzaga-Rcycs. Third Di\�ision]. Coca-Cola Bolllers Philippines, Inc. 1�. C'ommissio11er r?Onternal Rnenue. G.R. No. 222428. February 19.2018 [Per J. Peralta. Second Division]. t:astem Telecommunications PluhjJpi11es. Inc. 1'. Commissioner q( lntl!nwl Re1�enue. G.R. :..Jo. 183531. March 25.2015 [Per J. Reyes. Third Di\�isionl citingJ.R..-1. PhilljJpines. Inc. r. CIR. G.R. T\o. 171307. August 28.2013 [Per J. Perlas-Bernabe. Second Division].

DECISION CTA Case No. 11270 GE Healthcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue Page 22 of23 X-------------------------------------------------------------------------------------------X !CONCUR: \ BACORRO-VILLENA ATTESTATION I attest that the conclusions in the above Decision were reached in consultation before the case was assigned to the writer of the opinion of the Court's Division. ....- BACORRO-VILLENA Chairperson

DECISION CTA Case No. 11270 GE Healthcare Philippines, Inc. (formerly General Electric Philippines, Inc.) v. Commissioner of Internal Revenue Page 23 of23 x-------------------------------------------------------------------------------------------x CERTIFICATION Pursuant to Article VIII, Section 13 of the Constitution, and the First Division Acting Chairperson's Attestation, it is hereby certified that the conclusions in the above Decision were reached in consultation before the case was assigned to the writer of the opinion of the Court's Division. ~. ~ ~ ' - MA. BELEN M. RINGPIS-LIBAN Acting Presiding Justice

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