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

The Philippine Court of Tax Appeals March 19 issued a decision in CTA Case No. 10845, clarifying the validity of assessments for alleged tax deficiencies. The taxpayer, a domestic corporation, challenged assessments for deficiency income tax (IT), expanded withholding tax (EWT), withholding tax on compensation (WTC), and fringe benefit tax (FBT), alleging due process violations and the lack of a factual and legal basis. On appeal, the Court of Tax Appeals, Special Third Division, found that: 1) the FBT assessment was void because the Bureau of Internal Revenue (BIR) failed to substantiate its findings, particularly by not distinguishing between rank-and-file ...