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

The Philippine Court of Tax Appeals Nov. 4 issued a decision in CTA Case No. 10848, clarifying the validity of assessments for alleged tax deficiencies. The taxpayer, a corporation, challenged assessed deficiencies in income tax, VAT, expanded withholding tax, withholding tax on compensation, documentary stamp tax, and compromise penalty. The Commissioner of Internal Revenue (CIR) argued that the assessment notices and warrant were validly served and enforceable. On appeal, the Court of Tax Appeals, Second Division, found that: 1) the assessments and warrant weren’t validly served; 2) the Bureau of Internal Revenue (BIR) didn’t provide sufficient proof of mailing or ...