Philippines Court of Tax Appeals Issues Decision Clarifying Refund of Excess, Unutilized Creditable Withholding Taxes

Oct. 20, 2025, 5:00 AM UTC

The Philippine Court of Tax Appeals Oct. 10 issued a decision in CTA EB No. 2952, clarifying the refund of excess and unutilized creditable withholding taxes (CWTs). The taxpayer, a corporation, sought a refund of excess and unutilized CWTs for taxable year 2018. The Commissioner of Internal Revenue (CIR) contended that the taxpayer wasn’t entitled to the refund due to noncompliance with the specified requirements, and the taxpayer disagreed. The Court of Tax Appeals, Special First Division, granted the taxpayer’s refund claim for 2018, and the CIR appealed. On appeal, the Court of Tax Appeals, en banc, found that the ...

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