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

The Philippine Court of Tax Appeals Nov. 26 issued a decision in CTA Case No. 10789, clarifying the validity of assessments for alleged tax deficiencies. The taxpayer, a condominium association, challenged deficiency assessments for income tax (IT) and expanded withholding tax (EWT). The Commissioner of Internal Revenue argued, in part, that the taxpayer withdrew its administrative request for reconsideration. The taxpayer argued that the warrant of distraint and/or levy (WDL) was a denial of its reconsideration request. On appeal, the Court of Tax Appeals, Second Division, found that: 1) the WDL wasn’t a decision on the reconsideration request, so the ...