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

Jan. 21, 2026, 5:00 AM UTC

The Philippine Court of Tax Appeals Jan. 7 issued a decision in CTA EB No. 2883, clarifying the validity of assessments for alleged VAT deficiencies. The taxpayer, a domestic corporation, challenged a deficiency VAT assessment for the period from July 1, 2013, to June 30, 2014. The taxpayer argued that the assessment was void because the preliminary assessment notice (PAN) and formal letter of demand (FLD) lacked required annexes specifying the factual bases of the findings. On appeal, the Court of Tax Appeals, en banc, found that: 1) the assessment was void because the Bureau of Internal Revenue (BIR) failed ...

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