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

The Philippine Court of Tax Appeals April 21 issued a decision in CTA Case No. 10916, clarifying the validity of assessments for alleged tax deficiencies. The taxpayer, a corporation, challenged deficiency assessments, including for income tax, percentage tax, and penalties. The taxpayer argued in part that the Commissioner of Internal Revenue incorrectly presumed that undeclared purchases were made from undeclared taxable income. On appeal, the Court of Tax Appeals, Special First Division, found that: 1) the Commissioner issued the formal letter of demand (FLD) and final assessment notice (FAN) eight days after receiving the taxpayer’s reply to the preliminary assessment ...