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

The Philippine Court of Tax Appeals Dec. 10 issued a decision in CTA EB No. 2856, clarifying the validity of assessments for alleged tax deficiencies. The taxpayer, a multi-purpose cooperative, challenged deficiency tax assessments for VAT, expanded withholding tax (EWT), and compromise penalties for the taxable year 2006. The Commissioner of Internal Revenue (CIR) contended that the taxpayer was liable for the assessed deficiency taxes. The taxpayer argued that the assessments were void on various grounds, including because the Revenue Officers (ROs) continuing the conduct of the audit were allegedly not authorized through a Letter of Authority (LOA). On appeal, ...