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

The Philippine Court of Tax Appeals Feb. 5 issued a decision in CTA Case No. 10460, clarifying the validity of assessments for alleged tax deficiencies. The taxpayer, a wholly-owned company of the Singaporean government, sought a refund of final withholding tax (FWT) on interest income earned from Philippine treasury bonds, arguing exemption. The Commissioner of Revenue argued lack of reasonable opportunity to evaluate the administrative claim, when the judicial claim was filed 13 days after it. On appeal, the Court of Tax Appeals, Special Third Division, found that: 1) the administrative and judicial claims were timely filed within the two-year ...