Philippines Court of Tax Appeals Issues Decision Clarifying Validity of Assessments for Alleged Tax Deficiencies

The Philippine Court of Tax Appeals Nov. 3 issued a decision in CTA EB No. 2984, clarifying the validity of assessments for alleged tax deficiencies. The taxpayer, a domestic corporation, challenged assessed deficiencies in income tax, expanded withholding tax, and documentary stamp tax for 2008, arguing that preliminary and final notices were issued on the same day. The Commissioner of Internal Revenue (CIR) contended that due process was satisfied because the taxpayer was notified and able to contest the assessment. On appeal, the Court of Tax Appeals, en banc, found that: 1) the National Internal Revenue Code (NIRC) requires the ...