Philippines Court of Tax Appeals Issues Decision Clarifying Refunds of Unutilized, Excess Creditable Withholding Tax

The Philippine Court of Tax Appeals Feb. 16 issued a decision in CTA Case No. 10504, clarifying refunds of unutilized and excess creditable withholding tax (CWT). The taxpayer, a domestic corporation, sought a refund of excess CWT for taxable year (TY) 2018. The Commissioner of Internal Revenue (CIR) denied the taxpayer’s claim, citing the taxpayer’s failure to exhaust administrative remedies, alleged substantiation deficiencies, and insufficient proof of withholding. On appeal, the Court of Tax Appeals, Special Second Division, found that: 1) the specified claims were timely filed within the two-year prescriptive period; 2) the taxpayer sufficiently proved the fact of ...