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

The Philippine Court of Tax Appeals Nov. 7 issued a decision in CTA Case No. 10686, clarifying the validity of assessments for alleged tax deficiencies. The taxpayer, a domestic corporation, challenged assessed deficiencies in income tax, VAT, expanded withholding tax, final withholding tax, and documentary stamp tax, arguing that the assessments were void for lack of due process. On appeal, the Court of Tax Appeals, Third Division, found that: 1) the letter of authority (LOA) authorized two specific revenue officers (ROs) to examine the taxpayer’s books, but the case was subsequently transferred to two other ROs for examination and audit; ...