Competence. Integrity. Commitment.

COURT OF TAX APPEALS DECISIONS

TRUST FUND CONTRIBUTIONS BY PRE-NEED COMPANY IS EXCLUDED FROM GROSS RECEIPT FOR VAT PURPOSES; 19.75% UNDER-DECLARATION OF SALE WARRANTS THE APPLICATION OF 3-YEAR PRESCRIPTIVE PERIOD. Under the law, contributions to the trust fund are not included in the gross receipts of a pre-need company. Accordingly, when the taxpayer, as a pre-need company, made both initial trust fund contributions and subsequent additional contributions as required by the SEC, both amounts should be excluded in determining VAT liability. The BIR cannot validly exclude the initial contributions while including the additional ones in its VAT assessment. As to prescription, the BIR generally has three (3) years within which to issue an assessment. The period extends to ten (10) years only in cases the return is intentionally false or fraudulent. A prima facie presumption of falsity or fraud arises when there is an under-declaration of taxable sales exceeding thirty percent (30%) of the amount declared in the return. However, this presumption may be rebutted by the taxpayer upon showing that the discrepancy was due to inadvertence or error. In this case, the taxpayer demonstrated that the alleged under-declaration resulted from the BIR’s failure to exclude the additional trust fund contributions. Since the under-declaration amounted to only 19.75%, which is below the 30% threshold, the presumption of falsity does not apply. Consequently, the ordinary three-year prescriptive period governs. (CIR v. Pet Plans, Inc., CTA EB No. 2857, CTA Case No. 10002, September 2, 2025)

AN ASSESSMENT IS VOID WHEN THE EXAMINERS’ AUTHORITY TO AUDIT IS BASED ON MEMORANDUM OF ASSIGNMENT; CHIEF IS NOT AUTHORIZED TO ISSUE LETTER OF AUTHORITY; COURT MAY RULE ON EXAMINER’S LACK OF AUTHORITY EVEN NOT RAISED AS AN ISSUE. The Commissioner of Internal Revenue (CIR) or his duly authorized representatives, such as Regional Directors and Deputy Commissioners, have the authority to examine a taxpayer’s books of accounts; however, any reassignment of the examination to different revenue officers requires the issuance of a new Letter of Authority (LOA). A reassignment effected only through a Memorandum of Assignment (MOA), referral memorandum, or similar internal document, without a corresponding new LOA, constitutes a usurpation of the CIR’s authority, as an MOA cannot supplant or substitute for an LOA. Furthermore, a taxpayer’s failure to question the lack of authority does not bar the court from considering the issue, since it affects the intrinsic validity of the assessment itself. Thus, where an LOA originally authorized Revenue Officers Fernandez, Dizon, and Costales to conduct the audit, but the case was later reassigned to Examiners Benedicto and Santos without the issuance of a new LOA, relying only on a MOA signed by the Chief of Regular LT Audit Division II, who is not authorized to issue an LOA, the reassigned examiners lack legal authority, rendering the resulting assessment void. (CIR v. Metro Rail Transit Corporation, CTA EB No. 2862, CTA Case No. 9651, September 2, 2025)

ASSESSMENT BASED ON TAX VERIFICATION NOTICE (TVN), WITHOUT LOA, IS VOID. Under the National Internal Revenue Code, only the Commissioner of Internal Revenue or his duly authorized representative, specifically the Revenue Regional Director, may authorize the examination of a taxpayer through the issuance of a LOA and such authority may be exercised only in the manner expressly provided by law; jurisprudence consistently holds that an LOA is the exclusive and indispensable authority for a revenue officer to validly examine a taxpayer, the absence of which renders the assessment void for violation of due process. Applying these principles, a TVN issued by a Revenue District Officer cannot substitute for an LOA, as the NIRC, being a special law prevailing over the general provisions on agency under the Civil Code, does not recognize any equivalent document nor empower the Revenue Regional Director to delegate the issuance of LOAs through a TVN; thus, without a valid LOA authorizing the revenue officer’s examination, the resulting deficiency assessment is null and void. (CIR v. St. Paul Hospital Cavite, Inc., CTA EB No 2880, CTA Case No. 10815, August 15, 2025)

180-DAY PERIOD BASED ON INACTION IS COUNTED FROM THE FILING OF THE PROTEST AND NOT FROM APPEAL TO THE CIR. There is only one 180-day period reckoned from the filing of the protest or the submission of complete supporting documents. Thus, if the CIR’s duly authorized representative denies the protest within that 180-day period and the taxpayer elevates the matter to the CIR, the CIR is left with the balance of the same 180-day period to resolve the case. Should no action be taken within the remaining period, the taxpayer may appeal to the CTA within 30 days from the lapse thereof. Conversely, if the taxpayer opts to await the decision of the CIR’s representative and such decision is issued beyond the 180-day period, the taxpayer may still appeal the same to the CTA; in this situation, the 180-day period is no longer relevant, and the taxpayer’s recourse is to await the CIR’s final decision before seeking relief from the CTA if the ruling is adverse. (Benguet Electric Cooperative, Inc. (BENECO) vs. The Commissioner on Internal Revenue, CTA EB No. 2882, CTA Case No. 9667, September 2, 2025)

ASSESSMENT IS VOID IF THE BIR FAILED TO ADDRESS TAXPAYER’S ARGUMETNS IN THE PAN; VOID IF EXAMINER’S AUTHORITY IS MEMORANDUM OF ASSIGNMENT. Tax assessments must state in writing the factual and legal bases therefor and must be issued by revenue officers duly authorized through a valid LOA; otherwise, the assessments are void for violation of administrative due process and lack of authority, as consistently held in jurisprudence such as Avon Case. In this case, the BIR failed to address and consider the taxpayer’s refutations to the PAN, as the FLD merely reproduced the earlier findings without explaining the rejection of the defenses, thereby denying the taxpayer a meaningful opportunity to be heard; moreover, the deficiency assessments were recommended by a revenue officer who lacked a valid LOA at the time of the audit, her authority resting only on a Memorandum of Assignment issued by one not authorized to issue an LOA, rendering the examination and resulting assessments a nullity. Accordingly, the assessments were correctly declared void in  (CIR v. Will Team PH, Inc., CTA EB No. 2884, CTA Case No. 10154)

ASSESSMENT IS VOID IF NOT ALL EXAMINERS ARE NAMED IN THE LOA. Only the CIR or his duly authorized representatives—such as Revenue Regional Directors, Deputy Commissioners, Assistant Commissioners, and Head Revenue Executive Assistants—may issue a valid Letter of Authority (LOA) empowering revenue officers (ROs) to examine and audit a taxpayer’s books, and the LOA must specifically name the ROs performing the audit to satisfy due process; in this case, while the LOA for TY 2014 named ROs Pelayo, Guimbao, and GS Aviles, additional ROs Sison, Gomez, and Manuel participated in the examination without being named, tainting the audit with illegality and violating the taxpayer’s right to due process, and as a result, the Court of Tax Appeals in Division correctly nullified the 2014 deficiency tax assessments and enjoined the BIR from collecting them, (CIR V. Concepcion Industries, Inc., CTA EB No. 2920, CTA Case No. 10584 October 20, 2025)

30-DAY PERIOD TO FILE PETITION FOR REVIEW WITH THE CTA DIVISION IS NON-EXTENDIBLE. Under the National Internal Revenue Code of 1997, the 30-day period to appeal the Commissioner’s denial of a protest on a disputed assessment to the Court of Tax Appeals is mandatory and jurisdictional; failure to comply renders the assessment final, executory, and demandable, and such period cannot be extended by invoking Section 11 of Republic Act No. 1125 or Rule 42 of the Rules of Court, as the latter applies generally and yields to the specific substantive provision of Section 228. Here, the petitioner received the Final Decision on Disputed Assessment (FDDA) on July 15, 2024 and, instead of filing a Petition for Review within the 30-day period or until August 14, 2024, filed a Motion for Extension on August 13, 2024 seeking an additional 15 days; however, the Court En Banc held that it could not grant the extension because the appeal period under Section 228 is non-extendible, and procedural rules cannot override this statutory mandate. (Yokohama Tire Sales Philippines, Inc. v. CIR, CTA EB No. 3078, CTA Case No. 11590, October 24, 2025)

INTERCOMPANY LOAN IS NOT SUBJECT TO DST IF THE LOANED AMOUNT IS UTILIZED OUTSIDE  OF THE PHILIPPINES. Under Philippine law, documentary stamp tax (DST) is an excise tax imposed on transactions represented by documents, not on the documents themselves, and must be interpreted strictly against the government and liberally in favor of the taxpayer. DST on debt instruments applies only when the obligation or right arises from Philippine sources or when the object of the contract is located or used in the Philippines, reflecting the principle that a state’s taxing power is limited to subjects within its territorial jurisdiction. In the present case, Bloomberry’s loan agreements with its non-resident foreign affiliates were perfected outside the Philippines, as the loans were real contracts that required delivery of the proceeds, which were used in the Republic of Korea. Because the necessary jurisdictional connection, or situs, for DST is absent, the transactions cannot be taxed. Furthermore, the proviso in Section 173, which allows shifting of DST liability when one party is exempt, presupposes that the transaction is already taxable and does not create liability where none exists. Therefore, consistent with the legislative intent and the strict construction principle, Bloomberry’s loan transactions are not subject to DST. (CIR v. Bloomberry Resorts Corporation, CTA EB No. 2933, CTA Case No. 10193; Bloomberry Resorts Corporation v. CIR, CTA EB No. 2935, CTA Case No. 10193, August 6, 2025)

REVENUE ISSUANCES

BIR DEADLINES FROM FEBRUARY 23, 2026 TO FEBRUARY 28, 2026. A gentle reminder on the following deadlines, as may be applicable:

COURT OF TAX APPEALS DECISIONS

ASSESSMENT IS VOID IF THE BIR ISSUES FLD/FAN 3 WORKING DAYS AFTER TAXPAYER FILED ITS REPLY TO THE PAN, EVEN IF FLD/FAN IS ISSUED AFTER THE 15-DAY PERIOD REQUIREMENT. A taxpayer has 15 days from receipt of the PAN within which to submit a written response. Moreover, as part of due process, the BIR must address the taxpayer’s defenses, otherwise the assessment is void. Thus, where the taxpayer received the PAN on February 26, 2018 and filed a reply on March 9, 2018 (on the 11^th day), but the BIR issued the FAN on March 14, 2018 (even on the 16^th day from issuance of PAN but only after 5 calendar days or 3 working days from filing of reply), without indication that the reply was considered; where the FAN’s findings are mere verbatim of the findings in the PAN, save for interest, without acknowledging discussing or evaluating the defenses in the reply; where BIR changed the prescriptive period in the FAN from 3 years to 10 years without specifying the basis of the invocation. the assessment is void. (Folares Pharmaceuticals Inc. v. CIR, CTA Case No. 10331, October 27, 2025)

LOA REMAINS VALID AS LONG ONE EXAMINER HAS AUTHORITY EVEN THOUGH OTHER EXAMINERS DO NOT HAVE VALID AUTHORITY. Based on McDonald’s case, only the RO authorized in the LOA may conduct the audit. There is nothing in the McDonald’s case that states that the valid authority of the examiner is nullified or affected by the lack of authority of other revenue officers. Thus, where RO Sudano, Anaban and Monforte who prepared and signed the audit reports and memorandum were not authorized under the LOA, but RO Mendoza was authorized under the LOA to examine the books, the LOA remains valid despite other examiners lack authority (Grand Union Supermarket, Inc. v CIR,  CTA Case No. 10390, October 22, 2025)

A MEMORANDUM OF ASSIGNMENT SIGNED BY THE RDO IS NOT A LOA; RDO IS NOT AUTHORIZED TO ISSUE A LOA; A LOA BELATEDLY ISSUED AT THE REINVESTIGATION STAGE RENDERS THE ASSESSMENT VOID.  Under the Tax Code, a revenue officer must possess proper authorization to conduct an audit through a Letter of Authority (LOA), and jurisprudence holds that any reassignment of the examining officer necessitates the issuance of a new LOA. Only the Commissioner, Deputy Commissioner, Regional Directors, or officials duly authorized by the Commissioner may issue an LOA, meaning a Revenue District Officer (RDO) lacks such authority. In this case, since RO Dela Cruz and GS Lapuz, originally named in the LOA, were transferred or reassigned, and the audit was continued by RO Muti and GS Carim under a Memorandum of Assignment signed by the RDO, with a new LOA for GS Muti issued only after the taxpayer filed a Request for Re-Investigation following the PAN and FAN, the resulting assessment is rendered void. (Ebar Abstracting Company, Inc. v. CIR, CTA Case No. 10685, October 16, 2025)

AVON CASE WILL NOT APPLY IF THE REPLY TO THE PAN IS NOT SUPPORTED WITH DOCUMENTARY EVIDENCE. Due process requires that the assessment must state the fact and on which the assessment is based. In Avon Case, the Supreme Court ruled that the BIR is mandated not only to fully inform the taxpayer of the fact and law, but to comment or address the defenses and documents submitted by the taxpayer. Here, where the taxpayer’s protest to the PAN was not at all supported by any documentary evidence, despite the fact that it raised several factual issues that can be resolved by supporting documents. Thus, the BIR cannot be faulted if it merely reiterated the same findings, without giving any reason for rejecting the unsubstantiated refutations. Thus, Avon case does not apply. (TSPI Mutual Benefit Association, Inc. v. CIR, CTA Case No. 10691, October 14, 2025)

A COOPERATIVE IS EXEMPT FROM PERCENTAGE TAX ON LIFE INSURANCE PREMIUMS; REQUISITES. A cooperative association is exempt from paying taxes on life insurance premiums if it meets the following conditions: (1) it is managed by its members; (2) it operates using funds collected from its members; and (3) it is licensed for the mutual protection of its members rather than for profit. In this case, the taxpayer satisfies these requirements: the articles of incorporation grant each member one vote, all officers are members as confirmed by the General Information Sheet and minutes of meetings, the Mutual Benefit Association’s License classifies it as a nonstock, non-profit association providing death, medical, and similar benefits to members and their families, its revenue comes from member contributions and premiums, and the Insurance Commission’s license authorizes it to operate as a mutual benefit association. (TSPI Mutual Benefit Association, Inc. v. CIR, CTA Case No. 10691, October 14, 2025)

SUBSEQUENT BUYER OF THE PROPERTY SUBJECT TO NOTICE OF LIEN AND LEVY (NOTL) IS A REAL PARTY IN INTEREST; THE RUNNING OF THE PRESCRIPTIVE PERIOD FOR TAX COLLECTION IS SUSPENDED UPON THE VALID SERVICE OF A WARRANT OF DISTRAINT AND/OR LEVY (WDL), AND THE LAW DOES NOT PROVIDE FOR ANY AUTOMATIC RESUMPTION OF THE PERIOD ONCE SUSPENDED.  Where the BIR annotated Notices of Tax Lien and Levy (NOTL) on the taxpayer’s tax declarations covering certain real properties, and the taxpayer subsequently sold those properties to a buyer two years later, the buyer—although not the original taxpayer—qualifies as the real party-in-interest in challenging the validity of the NOTL. By acquiring the properties, the buyer likewise assumed the liabilities attached thereto. Being directly affected and potentially obliged to satisfy such liabilities, the buyer has a legal interest in seeking the lifting of the NOTL and stands to benefit from its cancellation.  Moreover, the Supreme Court in Republic v. Hizon, does not support the theory that prescription resumes after service of a WDL, but instead recognizes that summary collection proceedings may continue beyond the statutory period once seasonably initiated. Applying this, the CTA En Banc held that the BIR’s timely service of the WDL in 2011 validly suspended the prescriptive period; moreover, the advertisement and sale of the levied properties were not required to effect suspension. Consequently, the BIR’s right to collect the 2007 deficiency taxes did not prescribe, and there was no basis to lift the NOTL. (CIR v. Boast, Inc., CTA EB No. 2812, CTA Case No. 10484, September 16, 2025)

3-YEAR PRESCRIPTIVE PERIOD TO COLLECT APPLIES IF BIR FAILED TO PROVE BASIS FOR INVOKING THE 5-YEAR PRESCRIPTIVE PERIOD. Under Section 203 of the NIRC, internal revenue taxes shall be assessed within three years from the last day of filing the return, and once assessed, the BIR has another three years to collect; extraordinary periods under Section 222, allowing up to five years for collection, apply only in cases of fraud, false returns, or failure to file, which the BIR failed to prove. In this case, petitioner received the FAN on January 4, 2017, which became final and executory on February 3, 2017, and no evidence shows any protest, waiver, or exception to extend the period. Consequently, the regular three-year period to collect expired on February 3, 2020, and the issuance of the WDL on September 28, 2021, occurred well beyond this prescriptive period, rendering the BIR’s collection effort already prescribed. (Teknologix, Inc. v. CIR, CTA Case No. 10803, October 27, 2025)

BIR CANNOT ASSESS TAXPAYER BASED ON REVOKED RULING ON WHICH THE TAXPAYER RELIED ON ABSENT BAD FAITH. While the CIR has the authority to issue, modify, or revoke BIR rulings, any revocation cannot be given retroactive effect if it would prejudice a taxpayer who relied in good faith on a prior ruling, except in cases of misstatement of facts, materially different facts, or bad faith; moreover, applying the rule of expressio unius est exclusio alterius, only those rulings expressly revoked are deemed affected. Applying these principles, the CTA En Banc held that RMC No. 55-2010 expressly revoked only specific rulings issued to another taxpayer and did not include or expressly revoke Ruling No. 178-08 issued to the instant taxpayer, which was a specific interpretative ruling based on its distinct factual circumstances; absent proof of misrepresentation or bad faith, the taxpayer was entitled to rely on Ruling No. 178-08 in good faith, and the subsequent assessment for TY 2012, anchored on an implied revocation, would unjustly prejudice it. Accordingly, the deficiency assessment, FAN, and FDDA were properly cancelled. (CIR v. JTKC Land, Inc., CTA EB No. 2800, CTA Case No. 10059; JTKC Land, Inc. v. CIR, CTA EB No. 2808, CTA Case No. 10059, August 4, 2025)CTA MAY ORDER REFUND OF GARNISHED AMOUNT IN A DISPUTED ASSESSMENT CASE. The CTA may take cognizance of a petition for refund of taxes without requiring the prior filing of an administrative claim, particularly where such a requirement would be futile or result in unnecessary delay, as in cases involving disputed assessments or amounts paid under protest. Applying this to the present case, petitioner is entitled to the refund of the garnished amount of which was released by the bank to the BIR, because the deficiency assessments were null and requiring a prior administrative claim would have been a useless formality; accordingly, the Court properly entertained the Supplemental Petition for Review and found that the refund is in order. (The Philippine Stock Exchange, Inc. v. CIR, CTA Case No. 10781, July 4, 2025)

REVENUE ISSUANCES

Revenue Regulations No. 028-2025

Pursuant to Sections 244 and 245 of the National Internal Revenue Code, these regulations mandate the use of the Enhanced eDST System for specific industries for the affixation of documentary stamps.

Revenue Memorandum Circular No. 010-2026

Under the National Internal Revenue Code of 1997, cash donations must be filed through electronic platforms and supported by documentation, such as a notarized deed and proof of transfer, submitted to the BIR within thirty days. Notably, an Electronic Certificate Authorizing Registration (eCAR) is no longer required for these transactions because cash is not considered a registrable property requiring a formal transfer of title.

BIR DEADLINES FROM FEBRUARY 16, 2026 TO FEBRUARY 22, 2026. A gentle reminder on the following deadlines, as may be applicable:

We would like to share a VAT planning opportunity that may be particularly relevant to businesses with 70% export-related sales of goods and services.

Under the CREATE MORE Act (Republic Act No. 12066), VAT-registered exporters that meet the 70% export sales threshold for the preceding taxable year may apply for VAT zero-rating on local purchases through the Export Management Bureau (EMB) of the Department of Trade and Industry (DTI). Once approved, your local suppliers will no longer pass on VAT to you on qualified purchases.

This presents several practical advantages:

• No input VAT accumulation, as VAT is no longer passed on by suppliers
• No need to file VAT refund claims with the BIR or pursue costly and time-consuming cases before the CTA
• Improved cash flow, since VAT is no longer embedded in your purchase costs and tied up pending refund

Recent guidelines from the BIR highlights the importance of timely compliance. Under Revenue Memorandum Circular (RMC) No. 037-2025, for VAT refund claims covering periods beginning April 1, 2025, exporters who meet the 70% export threshold but fail to secure the required EMB VAT zero-rating certification will no longer be allowed to claim VAT refunds for VAT passed on by local suppliers. Instead, any unutilized input VAT may only be carried forward to future period despite the fact that export sales are VAT zero-rated. In short, without EMB certification, VAT may effectively become a stranded cost.

If this is something you would like to explore, we would be glad to walk you through the requirements, qualifying purchases, and implementation process to help you maximize the benefits under CREATE MORE.

Please let us know if you would like to schedule a discussion.

COURT OF TAX APPEALS DECISIONS

CERTIFICATE OF REGISTRATION WITH NATIONAL ELECTRIFICATION ADMINISTRATION (NEA) IS SUFFICIENT FOR NON-STOCK ELECTRIC COOPERATIVE TO BE EXEMPT FROM INCOME TAX. Electric Cooperatives registered with NEA are permanently exempted from income tax. Moreover, a registration with the Cooperative Development Authority is merely optional. Thus, where the taxpayer presented its Certificate its Registration with NEA, it becomes exempted from income tax. (Misamis Oriental Rural Electric Service Cooperative, Inc. (MORESCO 1), v. CIR, CTA Case No. 10987, October 15, 2025)

FORMAL LETTER OF DEMAND/FINAL ASSESSMENT NOTICE (FLD/FAN) ISSUED BEFORE THE LAPSE OF 15-DAY PERIOD TO REPLY TO THE PRELIMINARY ASSESSMEN NOTICE (PAN) IS VOID; A LETTER FOR EXTENSION BEFORE THE ISSUANCE OF THE FLD/FAN IS NOT CONSIDERED  A REPLY. As part of due process, the Tax Code and Revenue Regulations give taxpayer 15 days from receipt of the PAN to file a protest/response. It is only after the lapse of the 15-day period that the BIR may issue the corresponding FLD/FAN. Thus, where the PAN was received by the taxpayer on May 26, 2016, it has until June 10, 2016 to protest or respond to the PAN. Here, the BIR issued the FLD/FAN on June 7, 2016 before the lapse of the 15-day period. Moreover, a letter extension filed on June 6, 2016 after the issuance of the PAN and before the issuance of the FLD cannot be considered a reply to the PAN as it does not state any comment or argument against it. Thus, the taxpayer was not able to exhaust the 15-day period to respond to the PAN. Therefore, taxpayer’s due process was violated and the assessment is deemed void. (Pampanga Rural Electric Service Cooperative, Inc. v. CIR, CTA Case No. 10996. July 7, 2025; see also Getz Phrama (Phils.), Inc. v. CIR, CTA Case No. 9245)

BIR’S FAILURE TO SUFFICIENTLY AND ADEQUATELY EXPLAIN REJECTION OF TAXPAYER’S ARGUMENTS IN THE PAN (I.E. IMPOSITION OF 50% SURCHARGE WITHOUT SUFFICIENT EXPLANATION) RENDERS THE ASSESSMENT VOID; “MINIMUM” COMPLIANCE WITH DUE PROCESS IS NOT ACCEPTABLE. When a taxpayer protests an assessment, the BIR is required to address the arguments raised. Simply ignoring such arguments renders the assessment void, as that would be a violation of the taxpayer's right to due process. The BIR must acknowledge the taxpayer’s defenses and explain why the taxpayer’s argument is rejected. The BIR also cannot claim that it complied with the “minimum” due process.  Thus, where the taxpayer raised a number of arguments against the findings in the FAN (such as imposition of surcharge of 50%) such that taxpayer complained that the PAN failed to specifically allege the facts supporting the claim of false and fraudulent returns; the FAN failed to specify the specific returns filed by taxpayer which are false and fraudulent and the specific details made in the returns that the render them false or fraudulent; and the BIR failed to acknowledge the taxpayer’s arguments; the FAN and PAN are mostly identical, the assessment is void. (E.E. Black, Ltd. (Philippine Branch) v. CIR, CTA Case No. 11074)

BIR’S NOTICE OF DENIAL OF OFFER OF COMPROMISE BASED ON DOUBTFUL VALIDITY IS INVALID IF THE TAXPAYER’S APPLICATION IS BASED ON FINANCIAL INCAPACITY. Taxes may be compromised either based on reasonable doubt as to the validity of the claim (40% of the basic tax) or financial incapacity (10%). If the tax exceeds Php1M or the offer is less than the prescribed rates, the compromise must be approved by the National Evaluation Board (approved by the Commissioner and 4 deputy commissioners). The authority of the BIR is discretionary but should be exercised only within the bounds of law. Thus, where the taxpayer filed an offer of compromise based on financial incapacity, but the BIR evaluated the application based on doubtful validity as shown in the Resolution of the Regional Evaluation Board (REB) denying the offer of compromise, the BIR erroneously exercised its discretion within the parameters set by law. Such defect cannot be cured by the BIR’s answer or BIR witness. Thus, the Notice of Denial should be cancelled. Moreover, assuming that the Notice of Denial is valid based on doubtful validity, it remains invalid as the settlement offered is less than the prescribed minimum rates, and the evaluation of the REB is invalid without approval by the National Evaluation Board. (Spectrum Graphix, Inc. v. CIR, CTA Case No. 11117, 2025)

TAXPAYER CANNOT DISPUTE THE CORRECTNESS OF THE ASSESSMENT FOR FAILURE TO PROTEST THE ASSESSMENT; DUE DATE IN THE FAN, AND STATEMENT THEREIN THAT “INTEREST WILL BE ADJUSTED” WILL NOT AFFECT THE DEFINITENESS OF THE DEMAND; CTA MAY STILL RULE ON THE PRESCRIPTION TO COLLECT; OFFER OF COMPROMISE WILL NOT TOLL THE RUNNING OF 5-YEAR PRESCRIPTION TO COLLECT FOR FAILURE TO FILE RETURN. Tax assessment should be protested within 30 days from receipt thereof; otherwise, failure to protest will render the assessment final, executory and demandable.  Thus, where the BIR received the FAN on November 24, 2010 but taxpayer did not file a protest, the assessment becomes final, executory and demandable and the taxpayer cannot dispute the correctness of the assessment. Moreover, an assessment must contain a demand to pay tax, which must be a definite amount. Thus, where the FLD states that interest paid will be adjusted if paid after the date specified therein and the FAN states the due date for the payment (“please pay above amount or of before December 17, 2010”), the demand to pay is within a specific period and the amount is definite even if the interest will be adjusted, which is a logical consequence of imposing an interest. Moreover, the BIR has 3 years period to assess and another 3 years to collect. In case of failure to file return, the BIR has 10 years to assess and 5 years to collect. Collection could either be summary (by issuance of WDL) or judicial remedy (filing a complaint or filing an answer). Thus, where the taxpayer failed to file IAET return, BIR has 10 year to assess and 5 year to collect. Thus, where the assessment was received on November 24, 2010, the BIR has November 24, 2015 to collect. Here, the BIR did not initiate collection within these periods. Moreover,  the period to collect may be tolled or suspended, and  filing of an application for compromise settlement is not among the instances to interrupt the period to collect. Lastly, prescription to collect may be extended by a waiver. It should, among others be signed by the regional director and kind and amount of tax should be specified. Thus,  where a waiver was executed on April 24, 2013 to extend collection not later than December 17, 2016, was signed by the collection division, the waiver is invalid and the BIR’s right to collect has prescribed. (Spectrum Graphix, Inc. v. CIR, CTA Case No. 11117, 2025)

TAXPAYER MUST PRESENT TAX RETURNS TO INVOKE PRESCRIPTION. The BIR has 3 years to assess counted from the date of deadline to file the return or actual date of filing, whichever comes later. Prescription is a matter of defense, which means that the taxpayer must present evidence the pertinent tax returns for the concerned periods. Thus, where the taxpayer failed to offer in evidence its 2014 income tax return, Quarterly VAT returns and EWT returns, it cannot invoke prescription of the 2014 assessment. (Shirley Tan Festin v. CIR, CTA Case No. 10264, August 13, 2025)

FAILURE TO PROVE RECEIPT OF FAN/FLD, WHEN DENIED RECEIPT BY THE TAXPAYER, RENDERS THE ASSESSMENT VOID. When a BIR notice, such as the FLD/FAN was served via registered mail, taxpayer is presumed to receive it in the ordinary course of mail. When receipt is denied by the taxpayer, the BIR must prove actual receipt of the FLD/FAN. Thus, where during the trial, the BIR witnessed testified “I cannot see [the FLD] in the BIR records”, which means the BIR failed to prove that the FLD/FAN was served via registered mail,  due process is violated and assessment is void. (Shirley Tan Festin v. CIR, CTA Case No. 10264, August 13, 2025)

REVENUE ISSUANCES

Revenue Memorandum Circular No. 008-2026

The BIR has officially LIFTED its suspension of all tax audit and field operations pursuant to the previous RMC 107-2025.  All audit cases that were paused during the suspension period will now continue toward completion and the resumption covers all enforcement, verification, assessment, and collection activities that require audit or field presence.

Revenue Memorandum Order No. 1-2026

The RMO introduces the Single-Instance Audit Framework, which generally limits a taxpayer to one Electronic Letter of Authority (eLA) per taxable year covering all internal revenue tax types, including VAT to prevent fragmented or overlapping audits and promote transparency.

• Beginning 4 March 2026, all pending eLAs with ongoing investigations covering the same taxpayer and taxable year shall be automatically consolidated into one (1) eLA, without any action required from the taxpayer, except where a request for non-consolidation is allowed and filed.
• A consolidated replacement eLA shall be issued to cover all applicable internal revenue tax types for the taxable year concerned and shall be mandatorily conducted by the Revenue District Office (RDO) or Office Audit Section (OAS) of the Assessment Divisions for Regional Cases and Large Taxpayers (LT) Audit Divisions for Large Taxpayers Service (LTS) cases.
  • All eLAs subsumed in the consolidated eLA shall be deemed cancelled upon issuance of the replacement eLA.
  • NOTE: even prior the automatic cancellation date, nothing shall preclude the taxpayer from voluntarily settling assessed or admitted tax deficiencies through the modes allowed under existing issuances.
• Issuing multiple or overlapping eLAs for the same taxpayer and year is strictly prohibited. If the taxpayer wants to keep a VAT audit separate, a written request must be filed by February 16, 2026.
• New eLAs will be generated through information systems based on objective risk parameters. Taxpayer identities will remain concealed during the initial assignment of Revenue Officers (ROs) to prevent bias. Audit instruments must prominently display specific labels indicating their scope, such as "FULL EXAMINATION" for eLAs or "LIMITED SCOPE" for Tax Verification Notices (TVNs). The following are the possible triggers for the issuance of LOA.
  • Mandatory cases
    • Covered by a full audit notice (eLA)
      • Suspected fraud such as declaring 30% less income or 30% more expenses;
      • TP identified through specific industry knowledge, data from third parties, or publicly accessible information;
      • TP previously under a Mission Order where preliminary findings show a 30% or greater understatement of sales;
      • Transactions involving real property or other one-time events where review findings already indicate a tax deficiency;
      • Using tax exemptions or special incentives;
      • Noncompliance with tax obligations arising from Spontaneous Exchange of Information;
      • Тахраyers requesting for tax clearance whose gross sales is more than 1,000,000.00 or gross assets is more than 3,000,000.00, due to:
        • Death of the taxpayer; or 
        • Taxpayers retiring from business
        • Taxpayers undergoing merger/ consolidation/  split-up/ spin-off and;
        • other types of corporate reorganizations
  • Priority cases
    • Large drops in reported sales or VAT payments
    • Large increases in sales that are zero-rated or exempt from tax
    • Differences between current VAT filings and what was carried over from previous months
    • Claiming VAT credits that cover more than 75% of the tax actually owed
    • Paying income tax that is less than 2% of total sales
    • Reporting a net loss despite having large sales or seeing assets grow by 50%
    • Operating for more than five years without ever being audited
    • Claims for damages from natural disasters or for old inventory
    • Getting almost all income from a parent company or affiliate
    • Sharing large expenses between different branches or companies in a group. 
• Existing task forces created for audit functions (including the Run After Fake Transactions (RAFT) Task Force) are concluded, and their functions are absorbed by regular BIR offices. The VAT Audit Sections (VATAS) and Large Taxpayers VAT Audit Units (LTVAU) will wind up operations by May 15, 2026.
  • All existing LOAs issued under RAFT Task Force shall be considered cancelled for purposes of transition and replacement.
• To streamline audit procedures, Revenue Officers are now required to use a uniform checklist for document requests to minimize repetitive or unnecessary submissions. For voluminous records, taxpayers may opt to have the audit conducted at their principal place of business instead of transporting documents to the BIR.

Revenue Regulations No. 029-2025

Pursuant to Sections 4 and 244 in relation to Section 33 of the Tax Code of 1997, these regulations further amend RR No. 2-98 (as recently amended by RR No. 004-2025) to increase the ceiling of non-taxable "De Minimis" benefits exempt from income tax on compensation and fringe benefit tax.

BIR DEADLINES FROM FEBRUARY 1, 2026 TO FEBRUARY 8, 2026. A gentle reminder on the following deadlines, as may be applicable:

COURT OF TAX APPEALS (CTA) DECISIONS

AN ASSESSMENT IS VOID IF DUE DATES IN THE ASSESSMENT NOTICES WERE LEFT BLANK. Under the Tax Code and prevailing jurisprudence, an assessment must contain a demand of definite and fixed tax liability, within a specific period. Thus, where the Formal Letter of Demand (FLD) states that “please take note that the interest will have to be adjusted if paid beyond the date specified therein” but the accompanying Formal Assessment Notice (FAN) shows that the due dates were left blank, no proper demand within a specific period was validly made, thus, the assessment is void. (ePerformax Contact Centers (Cebu) Corp. v. Commissioner of Internal Revenue (CIR),  CTA Case No. 10572, September 9, 2025)

AN ASSESSMENT IS VOID IF THE BIR DID NOT PROVIDE EXPLANATIONS FOR REJECTING THE TAXPAYAYER’S ARGUMENTS IN ITS REPLY TO THE PRELIMINARY ASSESSMENT NOTICE (PAN). Under the Tax Code and prevailing jurisprudence, the taxpayer must be informed of the law and the facts on which the assessment is made, otherwise, the assessment is void. The BIR must give reason for rejecting the taxpayer’s explanations and must give the particular facts upon which his conclusions are based, especially as regards the adjustments made, and those facts must appear on record. Thus, where the assessments are similar to the findings in the PAN, except for the interest adjusted and compromise penalty imposed; the FLD did not address any explanations in the protest letter to the PAN; the details of discrepancy in the FAN was merely copied verbatim from the PAN; and the BIR did not provide sufficient explanation for the adjustment in the basic tax, the assessment is void (ePerformax Contact Centers (Cebu) Corp. v. CIR,  CTA Case No. 10572, September 9, 2025; see also BSFIL Technologies, Inc. v. CIR, CTA Case No. 10603, August 2025)

A WARRANT OF DISCTRAINT AND/OR LEVY ISSUED PENDING APPEAL WITH THE CIR IS VOID FOR BEING ISSUED PREMATURELY. The BIR may collect via distraint or levy in case of delinquency tax. Delinquency means that the taxpayer failed to pay within the period stated in the notice and demand and for which the taxpayer filed to file an appeal to the CTA or CIR within 30 days from receipt of the decision denying the request for reconsideration or reinvestigation. When the taxpayer timely appealed the Final Decision on Disputed Assessment (FDDA) to the CIR, the FDDA cannot be deemed final, executory or demandable as taxes are not yet delinquent, hence, the BIR cannot proceed with collection via WDL. Thus, where the taxpayer received the FDDA on August 25, 2020, and it appealed the same before the CIR on September 24, 2020, the WDL received on August 2, 2021, pending action of the CIR, is void for having been issued prematurely; moreover,  considering that the CIR has no decision yet, the CTA cannot rule on the validity of the assessment. (BSFIL Technologies, Inc. v. CIR, CTA Case No. 10603, August 2025)

A PROTEST IS A REQUEST FOR RECONSIDERATION IF THE TAXPAYER STATES SO AND IT FAILED TO SUBMIT ADDITIONAL DOCUMENTS WITHIN 60 DAYS. An assessment may be protested administratively by filing a request for reconsideration or reinvestigation, in such form and manner prescribed. “Form and manner” means that taxpayer must state the nature of the protest whether reconsideration or reinvestigation, and in case of reinvestigation, the taxpayer has 60 days to submit relevant supporting documents from filing of protest. Thus, where the taxpayer’s protest dated January 9, 2020 categorically refer to “request for reconsideration”, but it later on sent a letter dated March 9, 2020 clarifying that it is a request for reinvestigation, and there is no indication that the taxpayer submitted supporting documents to the BIR, the taxpayer belied its claim that its protest is a request for reinvestigation. (BSFIL Technologies, Inc. v. CIR, CTA Case No. 10603, August 2025)

PETITION IS DISMISSED IF FILED ONE-DAY LATE. The CTA has jurisdiction over other matters or cases that arise out of the NIRC or related laws administered by the  BIR. This includes issues on validity of the WDL and prescription. Appeal may be filed with the CTA 30 days from receipt of decision or ruling of the BIR. Thus, where the taxpayer received the WDL on June 14, 2021, but it filed the petition for review on July 15, 2021, or one day late, the CTA has no jurisdiction and the appeal should be dismissed. (Keys Realty and Development Corporation v. CIR, CTA Case no. 10589, July 7, 2025)

INACTION OF THE COMMISSIONER IS APPEALABLE TO THE CTA AFTER LAPSE OF 180 DAYS FROM FILING OF THE PROTEST, NOT FROM FILING OF REQUEST FOR RECONSIDATION BEFORE THE CIR. Under the Tax Code and jurisprudence, if CIR does not timely act on the protest, the options to either (a) file a Petition with the CTA under 180+30 rule from the filing of the protest; or (b) await the CIR's decision and file a Petition 30 days from receipt thereof, are mutually exclusive.  If the CIR does not act upon the protest and the taxpayer does not file a Petition within 30 days from the lapse of the 180-day period, the taxpayer's only recourse is to await the CIR's decision and file a Petition 30 days after that.  Thus, where the taxpayer protested the FAN on March 12, 2019, received the FDDA on November 23, 2021, but instead of filing a petition with the CTA, filed a Request for Reconsideration to the said FDDA on December 20, 2021, the counting of 180+30 days is from the filing of the protest, not on the filing of Request for Reconsideration. Therefore, the taxpayer had October 8, 2019 (180+30 days) to file the petition; and the petition based on inaction of the CIR, filed on July 18, 2022 or 210 days after its request for reconsideration, was filed out of time.(Empire Automation Phils. Inc., v. CIR, CTA Case No. 10924, September 15, 2025)

PETITION FILED OUTSIDE THE 30-DAY PERIOD FROM RECEIPT OF THE FDDA IS DISMISSIBLE; TAXPAYER CANNOT ARGUE THAT ITS ADMINISTRATIVE OFFICER HAS NO AUTHORITY TO RECEIVE THE FDDA WHEN THE PAN AND FLD WAS ALSO RECEIVED BY THE DESK RECEPTIONIST AND ADMINISTARTIVE SUERVISOR. The taxpayer has 30 days from receipt of the adverse decision of the CIR's duly authorized representative on the disputed assessment to file its appeal by way of Petition for Review before the CTA. Where the FDDA was received on March 6, 2020, the taxpayer has 30 days to file the petition until April 5, 2020. Thus, a petition filed on November 29, 2021 is belatedly filed.  Moreover, where the PAN and FAN were received by the desk receptionist and administrative supervisor, respectively, the taxpayer cannot question the service of the FDDA to an unauthorized person, if it was also signed received by its own administrative officer. (G2K Corporation v. CIR, CTA Case No. 10690, September 9, 2025)

ASSESSMENT IS VOID IF BIR FAILED TO PROVE THAT PAN WAS SERVED.  A PAN is a mandatory requirement of due process. It must be actually received by the taxpayer. If receipt is denied by the taxpayer, the BIR has the burden to prove that it was duly served. Thus, where the taxpayer denied receipt of the PAN and additional PAN; and BIR failed to provide evidence such as written report of service to actually show that the said documents were received by the taxpayer; and where during the trial, it was confirmed by the BIR witness that the BIR records failed to indicate that PAN was served, the taxpayer’s due process was violated. Moreover, the BIR cannot argue that the taxpayer should not be allowed to raise the issue for the first time on appeal which were not raised at the administrative level as the cases before the CTA are litigated de novo and the CTA can entertain arguments or even evidence not raised at the administrative level (Lakeside Food & Beverages Corp. v. CIR, CTA Case No. 10627, September 2025)

RECEIPT OF PAN AND FAN BY “PURCHASING OFFICER” AND “ASSISTANT LOGISTIC” IS VALID EVEN THOUGH NOT ALLEGEDLY AUTHORIZED BY THE TAXPAYER IF DURING TRIAL, THE WITNESS ADMITTED THAT THE SAID DOCUMENTS WERE RECEIVED BY THE TAXPAYER. Substituted service may be availed of only when it is shown that personal service is not practicable and when the party is not present at the registered or known address by leaving the assessment notices at the party's registered address, with “party’s clerk” or with a “person having charge” thereof. Where the taxpayer insists that the LOA, NIC, PAN and FAN were received by individuals not authorized representatives  (purchasing officer and assistant logistic) of the taxpayer to receive the same, but on trial, the witness, who has custody of the financial records, admitted that the same were received by the taxpayer, the service is proper and the taxpayer’s right to due process was not violated. (IBMS Technology Phils., Corporation v. CIR, CTA Case No. 10606, July 30, 2025)

SERVICE OF NOTICE OF INFORAL CONFERENCE (NIC), PAN AND FAN AFTER 180 DAYS FROM RECEIPT OF THE LOA WILL NOT RENDER THE ASSESSMENT VOID. Under the 2015 rules, a 180-day period for regional cases is prescribed to submit a report of investigation/verification but it does not state that the LOA shall be void if the period is not observed. Moreover, it also confirmed that that as early as 2010, a requirement to revalidate the LOA was withdrawn. Therefore, failure to revalidate the LOA does not affect the validity of the assessment; thus, where the BIR, served the LOA in 2018, but the NIC, PAN and FAN were served in 2020 or after 2 years from the receipt of the LOA, the taxpayer’s right is not violated. (IBMS Technology Phils., Corporation v. CIR, CTA Case No. 10606, July 30, 2025)

TAXES SHOULD BE ASSESSED WITHIN THE 3-YEAR PRESCRIPTIVE PERIOD BUT TAXPAYER SHOULD POINT OUT WHICH THE ASSESSED AMOUNT HAS PRESCRIBED. Internal revenue taxes should be assessed within 3 years from the date prescribed by law of the filing of the return or actual date of filing, whichever is later. Assessment refers to the service of the FAN. Thus, where the FAN was received on December 30, 2020, the assessment for 2017 for 1^st and 3^rd quarter VAT (should be assessed no later than October 25, 2020) and EWT for January to November, for 2017 (no later than December 13, 2020), have prescribed. However, the taxpayer should point out which portion of the assessment pertains to the prescribed tax. Thus, the entire assessment (for EWT) shall be considered as pertaining to the month of December 2017. (IBMS Technology Phils., Corporation v. CIR, CTA Case No. 10606, July 30, 2025)

TAXPAYER MAY BE ASSESSED FOR OVERCLAIMED DEPRECIATION FOR VEHICLES FOR FAILURE TO PROVE COST. Under the rules, only 1 vehicle for land transportation is allowable for depreciation per official or employee provided that the acquisition cost does not exceed Php2.4 Million. Thus, where the taxpayer failed to present proof that the acquisition cost of each vehicle did not exceed Php2.4. million threshold (i.e sales invoice, or deed of sale to prove the purchase price),, and that only 1 vehicle was assigned per employee, overclaimed depreciation is sustained. (IBMS Technology Phils., Corporation v. CIR, CTA Case No. 10606, July 30, 2025)

VAT-ZERO RATED SALES REQUIRES PEZA CERTIFICATION AND INVOICE/RECEIPTS COMPLIANT WITH INVOICING REQUIREMENTS. To determine whether sales are subject to zero-rated VAT, the following are the requirements: 1. Sale was made by VAT registered person and sale was made to an entity entitled to incentives under EO No. 226. For the first element, where the taxpayer failed to submit BIR Form 2303 to establish that is a VAT-registered person, the ORs and billing statements and FAN revealing the VAT registration of the taxpayer are sufficient. For the second requisite, the taxpayer must submit the invoice or official receipts and proof of zero rating. Where the taxpayer submitted sales invoice as proof of sale and PEZA certifications as proof of entitlement to zero-rating, but invoice does not comply with invoicing requirements (OR failed to indicate nature of service; OR failed to indicate the transactions as zero-rated), due to lack of proper substantiation, portion of zero-rated sales should be disallowed. (IBMS Technology Phils., Corporation v. CIR, CTA Case No. 10606, July 30, 2025)

EXCESS INPUT VAT MAY NOT BE APPLIED IF USED IN THE SUBSUQUENT QUARTER/S Under the NIRC, excess input VAT can be carried over to the succeeding quarters. Since, it will be offset to the output tax in subsequent period, it may redound to the benefit of the taxpayer in such future period. Thus, the taxpayer must prove that the input tax was not utilized in the succeeding quarter/s Thus, where the taxpayer failed to provide evidence to establish that the excess input tax was not carried over or applied in the succeeding period, ensuring that the taxpayer will not benefit twice from the same input tax credits (1) as deduction from the current assessment and (2) as credits against output tax liability in succeeding taxable quarter/period, the BIR correctly points out that the excess was not applied against the allowable input tax. (IBMS Technology Phils., Corporation v. CIR, CTA Case No. 10606, July 30, 2025)

REVENUE ISSUANCES

Revenue Memorandum Circular No. 04-2026

Extension of Registration Deadlines

Revenue Regulations No. 25-2025

The Bureau of Internal Revenue has suspended the mandatory excise tax bond for petroleum importers and manufacturers under Section 5 of RA 11032 and Section 160 of the Tax Code, recognizing the bond as a redundant cost since taxes are already settled prior to the release of goods.

Revenue Regulations No. 26-2025

Pursuant to Sections 244 and 245 of the National Internal Revenue Code, in relation to Sections 12 and 13 of Republic Act No. 12066 (CREATE MORE Act), the Bureau of Internal Revenue has extended the compliance deadline for the issuance of electronic invoices to December 31, 2026, for specific groups including e-commerce entities, Large Taxpayers, and users of Computerized Accounting Systems to allow for necessary system reconfigurations.

Revenue Regulations No. 27-2025

The Bureau of Internal Revenue has updated the tax rules for the sale of tax-exempt vehicles to non-exempt buyers, imposing a 16% annual depreciation rate (capped at 80%) for tax base computation, while disqualifying any depreciation if the transaction is found to be a scheme to circumvent excise taxes.

BIR RULINGS

DEFENSE CONTRACTOR IS ENTITLED TO INCOME TAX AND VAT INCENTIVES FOR ITS REGISTERED PROJECTS AND TAX-EXEMPT IMPORTATIONS OF NON-LOCALLY AVAILABLE DEFENSE MATERIAL, SUBJECT TO THE FULFILLMENT OF EXPORT REQUIREMENTS AND SPECIFIC REGISTRATION CONDITIONS. Pursuant to the provisions of Republic Act No. 11534, as amended by Republic Act No. 12066, and the Self-Reliant Defense Posture Revitalization Act (RA No. 12024), Registered Business Enterprises (RBEs) engaged in the manufacture of defense material are granted incentives such as Income Tax Holidays, a 5% Special Corporate Income Tax, and VAT exemptions on local purchases and importations of capital equipment and raw materials not locally available. In this case, the subject domestic enterprise, which manufactures firearms and ammunition for government agencies, possesses multiple BOI-registered projects that qualify for these fiscal benefits; however, the application of these facts confirms that the entitlement to incentives for specific projects is contingent upon meeting the 70% export threshold, and the exemption from national internal revenue taxes and VAT on imported materiel is restricted exclusively to items that cannot be sourced within the local market. (BIR RULING NO. OT-207-2025, October 28, 2025)

PAYMENTS FOR AIRPORT-RELATED FEES AND RENTALS MADE TO A GOVERNMENT AIRPORT AUTHORITY ARE EXEMPT FROM CREDITABLE WITHHOLDING TAX BECAUSE SUCH REVENUES CONSTITUTE INCOME DERIVED FROM THE EXERCISE OF ESSENTIAL GOVERNMENTAL FUNCTIONS EXCLUDED FROM GROSS INCOME. Pursuant to Section 32 (B) (7) (b) of the National Internal Revenue Code of 1997, as amended, and as supported by Executive Order No. 292, income derived by the Government or its political subdivisions from any public utility or from the exercise of essential governmental functions is excluded from gross income and exempt from taxation. Applying these laws to the facts, the subject international air carrier is not required to withhold taxes on payments made to the national airport authority for landing fees, rentals, and utility charges; while the passage of RA No. 11659 reclassified the airport authority from a "public utility" to a "public service," it remains a government instrumentality whose primary mandate providing safe and efficient airport facilities—is an essential governmental function rather than a proprietary one, thereby rendering its operational income exempt from income tax and the corresponding creditable withholding tax. (BIR Ruling No. OT-217-2025, November 12, 2025)

BIR DEADLINES FROM JANUARY 26 TO JANUARY 31, 2026. A gentle reminder on the following deadlines, as may be applicable:

DATE	FILING/SUBMISSION
January 29, 2026	e-FILING & PAYMENT (Online/Manual) – BIR Form 1702Q (Quarterly Income Tax Return For Corporations, Partnerships and Other Non-Individual Taxpayers) and Summary Alphalist of Withholding Taxes (SAWT).   Fiscal Quarter ending November 30, 2025
January 30, 2026	SUBMISSION – Proof of e-Filed BIR Form 1702-RT/1702-EX/1702-MX with Audited Financial Statements (AFS), 1709 (if applicable), and Other Attachments through Electronic Audited Financial Statements (eAFS).   Fiscal Year ending September 30, 2025
	SUBMISSION – Soft Copies of Inventory List and Schedules stored and saved in DVD-R/USB properly labeled together with a Notarized Sworn Declaration.   Calendar Year ending December 31, 2025
	e-SUBMISSION – Quarterly Summary List of Sales/Purchases/Importations by a VAT Registered Taxpayers – eFPS Filers.   For the Quarter ending December 31, 2025
	ONLINE REGISTRATION (thru ORUS) – Computerized Books of Accounts and Other Accounting Records.   Calendar Year ending December 31, 2025
January 31, 2026	DISTRIBUTION – BIR Form 2316 (Certificate of Compensation Payment/Tax Withheld – For Compensation Payment With or Without Tax Withheld) to the Employees.   Calendar Year 2025
	SUBMISSION – Sworn Declaration of Motels & Other Similar Establishments.   Taxable Year 2025
	SUBMISSION – Sworn Statement by Senior Citizens whose Annual Income does not exceed the poverty level as determined by NEDA thru the NSCB.   Taxable Year 2025
	SUBMISSION – Annual Information by all Accredited Tax Agents/Practitioners to be submitted to RNAB/RRAB.   Taxable Year 2025
	SUBMISSION – Annual Alphabetical List of Professionals/Persons who were issued Professional/Occupational Tax Receipt (PTR/OTR) by LGUs.   Calendar Year ending December 31, 2025
	SUBMISSION – Sworn Certification from the International Carrier stating that there is no change in the Domestic Laws of its Home Country Granting Income Tax Exemption to Philippine Carriers.   Calendar Year 2026 for Exemptions issued in 2025
	SUBMISSION – Notarized Income Payor/Withholding Agent’s Sworn Declaration with List of Payees Not   Subjected To Withholding Tax.   Calendar Year 2026
	SUBMISSION – Contract of Lease and Lessee Information Statement and Other Attachments by Lessors/Sub-Lessors of Commercial Establishments, Buildings or Spaces for Tenants.   2nd Semester of 2025
	SUBMISSION – Sworn Statement by every Lessee/Concessionaire/Owner/Operator of Mines or Quarry/Processor of Minerals/Producers or Manufacturers of Mineral Products.   2nd Semester of 2025
	e-FILING – BIR Form 1604-C (Annual Information Return of Income Taxes Withheld on Compensation) and/or BIR Form 1604-F (Annual Information Return of Income Payments Subjected to Final Withholding Taxes) and Related Alphalist.   Calendar Year 2025
	e-FILING & PAYMENT (Online/Manual) – BIR Form 1601-EQ (Quarterly Remittance Return of Creditable Income Taxes Withheld-Expanded) and Quarterly Alphalist of Payees (QAP) – eFPS & Non-eFPS Filers.   For the Quarter ending December 31, 2025
	e-FILING & PAYMENT (Online/Manual) – BIR Form 1601-FQ (Quarterly Remittance Return of Final Income Taxes Withheld) and Quarterly Alphalist of Payees (QAP) – eFPS & Show More COURT OF TAX APPEALS (CTA) DECISIONS AN ASSESSMENT IS VOID IF DUE DATES IN THE ASSESSMENT NOTICES WERE LEFT BLANK. Under the Tax Code and prevailing jurisprudence, an assessment must contain a demand of definite and fixed tax liability, within a specific period. Thus, where the Formal Letter of Demand (FLD) states that “please take note that the interest will have to be adjusted if paid beyond the date specified therein” but the accompanying Formal Assessment Notice (FAN) shows that the due dates were left blank, no proper demand within a specific period was validly made, thus, the assessment is void. (ePerformax Contact Centers (Cebu) Corp. v. Commissioner of Internal Revenue (CIR),  CTA Case No. 10572, September 9, 2025) AN ASSESSMENT IS VOID IF THE BIR DID NOT PROVIDE EXPLANATIONS FOR REJECTING THE TAXPAYAYER’S ARGUMENTS IN ITS REPLY TO THE PRELIMINARY ASSESSMENT NOTICE (PAN). Under the Tax Code and prevailing jurisprudence, the taxpayer must be informed of the law and the facts on which the assessment is made, otherwise, the assessment is void. The BIR must give reason for rejecting the taxpayer’s explanations and must give the particular facts upon which his conclusions are based, especially as regards the adjustments made, and those facts must appear on record. Thus, where the assessments are similar to the findings in the PAN, except for the interest adjusted and compromise penalty imposed; the FLD did not address any explanations in the protest letter to the PAN; the details of discrepancy in the FAN was merely copied verbatim from the PAN; and the BIR did not provide sufficient explanation for the adjustment in the basic tax, the assessment is void (ePerformax Contact Centers (Cebu) Corp. v. CIR,  CTA Case No. 10572, September 9, 2025; see also BSFIL Technologies, Inc. v. CIR, CTA Case No. 10603, August 2025) A WARRANT OF DISCTRAINT AND/OR LEVY ISSUED PENDING APPEAL WITH THE CIR IS VOID FOR BEING ISSUED PREMATURELY. The BIR may collect via distraint or levy in case of delinquency tax. Delinquency means that the taxpayer failed to pay within the period stated in the notice and demand and for which the taxpayer filed to file an appeal to the CTA or CIR within 30 days from receipt of the decision denying the request for reconsideration or reinvestigation. When the taxpayer timely appealed the Final Decision on Disputed Assessment (FDDA) to the CIR, the FDDA cannot be deemed final, executory or demandable as taxes are not yet delinquent, hence, the BIR cannot proceed with collection via WDL. Thus, where the taxpayer received the FDDA on August 25, 2020, and it appealed the same before the CIR on September 24, 2020, the WDL received on August 2, 2021, pending action of the CIR, is void for having been issued prematurely; moreover,  considering that the CIR has no decision yet, the CTA cannot rule on the validity of the assessment. (BSFIL Technologies, Inc. v. CIR, CTA Case No. 10603, August 2025) A PROTEST IS A REQUEST FOR RECONSIDERATION IF THE TAXPAYER STATES SO AND IT FAILED TO SUBMIT ADDITIONAL DOCUMENTS WITHIN 60 DAYS. An assessment may be protested administratively by filing a request for reconsideration or reinvestigation, in such form and manner prescribed. “Form and manner” means that taxpayer must state the nature of the protest whether reconsideration or reinvestigation, and in case of reinvestigation, the taxpayer has 60 days to submit relevant supporting documents from filing of protest. Thus, where the taxpayer’s protest dated January 9, 2020 categorically refer to “request for reconsideration”, but it later on sent a letter dated March 9, 2020 clarifying that it is a request for reinvestigation, and there is no indication that the taxpayer submitted supporting documents to the BIR, the taxpayer belied its claim that its protest is a request for reinvestigation. (BSFIL Technologies, Inc. v. CIR, CTA Case No. 10603, August 2025) PETITION IS DISMISSED IF FILED ONE-DAY LATE. The CTA has jurisdiction over other matters or cases that arise out of the NIRC or related laws administered by the  BIR. This includes issues on validity of the WDL and prescription. Appeal may be filed with the CTA 30 days from receipt of decision or ruling of the BIR. Thus, where the taxpayer received the WDL on June 14, 2021, but it filed the petition for review on July 15, 2021, or one day late, the CTA has no jurisdiction and the appeal should be dismissed. (Keys Realty and Development Corporation v. CIR, CTA Case no. 10589, July 7, 2025) INACTION OF THE COMMISSIONER IS APPEALABLE TO THE CTA AFTER LAPSE OF 180 DAYS FROM FILING OF THE PROTEST, NOT FROM FILING OF REQUEST FOR RECONSIDATION BEFORE THE CIR. Under the Tax Code and jurisprudence, if CIR does not timely act on the protest, the options to either (a) file a Petition with the CTA under 180+30 rule from the filing of the protest; or (b) await the CIR’s decision and file a Petition 30 days from receipt thereof, are mutually exclusive.  If the CIR does not act upon the protest and the taxpayer does not file a Petition within 30 days from the lapse of the 180-day period, the taxpayer’s only recourse is to await the CIR’s decision and file a Petition 30 days after that.  Thus, where the taxpayer protested the FAN on March 12, 2019, received the FDDA on November 23, 2021, but instead of filing a petition with the CTA, filed a Request for Reconsideration to the said FDDA on December 20, 2021, the counting of 180+30 days is from the filing of the protest, not on the filing of Request for Reconsideration. Therefore, the taxpayer had October 8, 2019 (180+30 days) to file the petition; and the petition based on inaction of the CIR, filed on July 18, 2022 or 210 days after its request for reconsideration, was filed out of time.(Empire Automation Phils. Inc., v. CIR, CTA Case No. 10924, September 15, 2025) PETITION FILED OUTSIDE THE 30-DAY PERIOD FROM RECEIPT OF THE FDDA IS DISMISSIBLE; TAXPAYER CANNOT ARGUE THAT ITS ADMINISTRATIVE OFFICER HAS NO AUTHORITY TO RECEIVE THE FDDA WHEN THE PAN AND FLD WAS ALSO RECEIVED BY THE DESK RECEPTIONIST AND ADMINISTARTIVE SUERVISOR. The taxpayer has 30 days from receipt of the adverse decision of the CIR’s duly authorized representative on the disputed assessment to file its appeal by way of Petition for Review before the CTA. Where the FDDA was received on March 6, 2020, the taxpayer has 30 days to file the petition until April 5, 2020. Thus, a petition filed on November 29, 2021 is belatedly filed.  Moreover, where the PAN and FAN were received by the desk receptionist and administrative supervisor, respectively, the taxpayer cannot question the service of the FDDA to an unauthorized person, if it was also signed received by its own administrative officer. (G2K Corporation v. CIR, CTA Case No. 10690, September 9, 2025) ASSESSMENT IS VOID IF BIR FAILED TO PROVE THAT PAN WAS SERVED.  A PAN is a mandatory requirement of due process. It must be actually received by the taxpayer. If receipt is denied by the taxpayer, the BIR has the burden to prove that it was duly served. Thus, where the taxpayer denied receipt of the PAN and additional PAN; and BIR failed to provide evidence such as written report of service to actually show that the said documents were received by the taxpayer; and where during the trial, it was confirmed by the BIR witness that the BIR records failed to indicate that PAN was served, the taxpayer’s due process was violated. Moreover, the BIR cannot argue that the taxpayer should not be allowed to raise the issue for the first time on appeal which were not raised at the administrative level as the cases before the CTA are litigated de novo and the CTA can entertain arguments or even evidence not raised at the administrative level (Lakeside Food & Beverages Corp. v. CIR, CTA Case No. 10627, September 2025) RECEIPT OF PAN AND FAN BY “PURCHASING OFFICER” AND “ASSISTANT LOGISTIC” IS VALID EVEN THOUGH NOT ALLEGEDLY AUTHORIZED BY THE TAXPAYER IF DURING TRIAL, THE WITNESS ADMITTED THAT THE SAID DOCUMENTS WERE RECEIVED BY THE TAXPAYER. Substituted service may be availed of only when it is shown that personal service is not practicable and when the party is not present at the registered or known address by leaving the assessment notices at the party’s registered address, with “party’s clerk” or with a “person having charge” thereof. Where the taxpayer insists that the LOA, NIC, PAN and FAN were received by individuals not authorized representatives  (purchasing officer and assistant logistic) of the taxpayer to receive the same, but on trial, the witness, who has custody of the financial records, admitted that the same were received by the taxpayer, the service is proper and the taxpayer’s right to due process was not violated. (IBMS Technology Phils., Corporation v. CIR, CTA Case No. 10606, July 30, 2025) SERVICE OF NOTICE OF INFORAL CONFERENCE (NIC), PAN AND FAN AFTER 180 DAYS FROM RECEIPT OF THE LOA WILL NOT RENDER THE ASSESSMENT VOID. Under the 2015 rules, a 180-day period for regional cases is prescribed to submit a report of investigation/verification but it does not state that the LOA shall be void if the period is not observed. Moreover, it also confirmed that that as early as 2010, a requirement to revalidate the LOA was withdrawn. Therefore, failure to revalidate the LOA does not affect the validity of the assessment; thus, where the BIR, served the LOA in 2018, but the NIC, PAN and FAN were served in 2020 or after 2 years from the receipt of the LOA, the taxpayer’s right is not violated. (IBMS Technology Phils., Corporation v. CIR, CTA Case No. 10606, July 30, 2025) TAXES SHOULD BE ASSESSED WITHIN THE 3-YEAR PRESCRIPTIVE PERIOD BUT TAXPAYER SHOULD POINT OUT WHICH THE ASSESSED AMOUNT HAS PRESCRIBED. Internal revenue taxes should be assessed within 3 years from the date prescribed by law of the filing of the return or actual date of filing, whichever is later. Assessment refers to the service of the FAN. Thus, where the FAN was received on December 30, 2020, the assessment for 2017 for 1st and 3rd quarter VAT (should be assessed no later than October 25, 2020) and EWT for January to November, for 2017 (no later than December 13, 2020), have prescribed. However, the taxpayer should point out which portion of the assessment pertains to the prescribed tax. Thus, the entire assessment (for EWT) shall be considered as pertaining to the month of December 2017. (IBMS Technology Phils., Corporation v. CIR, CTA Case No. 10606, July 30, 2025) TAXPAYER MAY BE ASSESSED FOR OVERCLAIMED DEPRECIATION FOR VEHICLES FOR FAILURE TO PROVE COST. Under the rules, only 1 vehicle for land transportation is allowable for depreciation per official or employee provided that the acquisition cost does not exceed Php2.4 Million. Thus, where the taxpayer failed to present proof that the acquisition cost of each vehicle did not exceed Php2.4. million threshold (i.e sales invoice, or deed of sale to prove the purchase price),, and that only 1 vehicle was assigned per employee, overclaimed depreciation is sustained. (IBMS Technology Phils., Corporation v. CIR, CTA Case No. 10606, July 30, 2025) VAT-ZERO RATED SALES REQUIRES PEZA CERTIFICATION AND INVOICE/RECEIPTS COMPLIANT WITH INVOICING REQUIREMENTS. To determine whether sales are subject to zero-rated VAT, the following are the requirements: 1. Sale was made by VAT registered person and sale was made to an entity entitled to incentives under EO No. 226. For the first element, where the taxpayer failed to submit BIR Form 2303 to establish that is a VAT-registered person, the ORs and billing statements and FAN revealing the VAT registration of the taxpayer are sufficient. For the second requisite, the taxpayer must submit the invoice or official receipts and proof of zero rating. Where the taxpayer submitted sales invoice as proof of sale and PEZA certifications as proof of entitlement to zero-rating, but invoice does not comply with invoicing requirements (OR failed to indicate nature of service; OR failed to indicate the transactions as zero-rated), due to lack of proper substantiation, portion of zero-rated sales should be disallowed. (IBMS Technology Phils., Corporation v. CIR, CTA Case No. 10606, July 30, 2025) EXCESS INPUT VAT MAY NOT BE APPLIED IF USED IN THE SUBSUQUENT QUARTER/S Under the NIRC, excess input VAT can be carried over to the succeeding quarters. Since, it will be offset to the output tax in subsequent period, it may redound to the benefit of the taxpayer in such future period. Thus, the taxpayer must prove that the input tax was not utilized in the succeeding quarter/s Thus, where the taxpayer failed to provide evidence to establish that the excess input tax was not carried over or applied in the succeeding period, ensuring that the taxpayer will not benefit twice from the same input tax credits (1) as deduction from the current assessment and (2) as credits against output tax liability in succeeding taxable quarter/period, the BIR correctly points out that the excess was not applied against the allowable input tax. (IBMS Technology Phils., Corporation v. CIR, CTA Case No. 10606, July 30, 2025) REVENUE ISSUANCES Revenue Memorandum Circular No. 04-2026 Date Issued January 15, 2026 Subject Clarification on the Mandatory Registration of Permanently Bound Loose-Leaf Books of Accounts and Computerized Books of Accounts Through the Online Registration and Update System (ORUS), and Extension of Registration Deadlines Mandatory Online Registration The registration of Permanently Bound Loose-Leaf Books of Accounts and Computerized Books of Accounts must be completed strictly through the Online Registration and Update System (ORUS). Manual Registration Manual registration at a Revenue District Office (RDO) is only permitted if there is a documented system downtime or if an official advisory regarding ORUS unavailability has been issued. Validation and Compliance Upon successful registration, the system generates a QR Code stamp. Loose-Leaf Books: The QR Code must be affixed to the first page of the bound books. Computerized Books: The QR Code should be printed and kept for records. Extension of Registration Deadlines REGISTRATION DEADLINE EXTENSION Registration of Permanently Bound Loose-Leaf Books of Accounts/Invoices and Other Accounting Records January 15, 2026 January 31, 2026 Registration of Computerized Books of Accounts and Other Accounting Records January 30, 2026 February 17, 2026 Revenue Regulations No. 25-2025 The Bureau of Internal Revenue has suspended the mandatory excise tax bond for petroleum importers and manufacturers under Section 5 of RA 11032 and Section 160 of the Tax Code, recognizing the bond as a redundant cost since taxes are already settled prior to the release of goods. Subject Temporary Suspension of the Excise Tax Bond Requirement Legal Justification The bond is deemed an “undue regulatory burden” because excise taxes are already paid prior to the release of oil from customs or refineries. Scope Petroleum Industry Importers & Manufacturers Compliance and Reporting Must be duly registered with both the BIR and BOC and have a history of substantial tax law compliance. Importers must still secure an Authority to Release Imported Goods (ATRIG) via the National Single Window before any product withdrawal. Entities must submit a monthly report to the BIR/BOC detailing volumes, invoice values, and actual tax payments made. Implementation The suspension remains in effect until the Anti-Red Tape Authority (ARTA) completes its review for a potential permanent repeal of the law. Revenue Regulations No. 26-2025 Pursuant to Sections 244 and 245 of the National Internal Revenue Code, in relation to Sections 12 and 13 of Republic Act No. 12066 (CREATE MORE Act), the Bureau of Internal Revenue has extended the compliance deadline for the issuance of electronic invoices to December 31, 2026, for specific groups including e-commerce entities, Large Taxpayers, and users of Computerized Accounting Systems to allow for necessary system reconfigurations. Subject Extension Of Issuance Of Electronic Invoices By E-Commerce Sector (Small To Large), Those Under The Large Taxpayers Service, And Users Of Computerized Accounting Systems (CAS) Purpose The extension aligns with national policy to allow “operational adjustments” during the shift to digital tax administration. E-Commerce Sector All Small, Medium, Large taxpayers are mandated to comply with the electronic invoicing requirements Micro Taxpayers are explicitly exempted from the mandatory electronic invoicing requirements. Exporters & POS Users Compliance for exporters, RBEs, and POS users is deferred until the BIR establishes a system capable of processing the required data. Electronic Sales Reporting System Covered taxpayers will eventually be mandated to report sales electronically once separate specific regulations are issued. Revenue Regulations No. 27-2025 The Bureau of Internal Revenue has updated the tax rules for the sale of tax-exempt vehicles to non-exempt buyers, imposing a 16% annual depreciation rate (capped at 80%) for tax base computation, while disqualifying any depreciation if the transaction is found to be a scheme to circumvent excise taxes. Subject Valuation and tax treatment of tax-exempt automobiles when they are sold or transferred to non-exempt persons Purpose To ensure it reflects fair market conditions and prevents revenue loss. Tax Base The tax is calculated on either the selling price or the book value, whichever is greater. Depreciation Rate A standardized 16% yearly reduction is allowed, but it cannot exceed 80% of the original cost. Zero-Depreciation Penalty If “intent to circumvent” is found, the tax is based on the original price without any deductions. Short-term Ownership Selling a vehicle within one year without valid operational justification suggests a tax-evasion intent. Affiliated Transfers Selling to employees or relatives without documented fair market value triggers an investigation into the transaction’s validity. Operational Use The BIR may now inspect mileage logs and maintenance records to verify the vehicle was actually used for official purposes. BIR RULINGS DEFENSE CONTRACTOR IS ENTITLED TO INCOME TAX AND VAT INCENTIVES FOR ITS REGISTERED PROJECTS AND TAX-EXEMPT IMPORTATIONS OF NON-LOCALLY AVAILABLE DEFENSE MATERIAL, SUBJECT TO THE FULFILLMENT OF EXPORT REQUIREMENTS AND SPECIFIC REGISTRATION CONDITIONS. Pursuant to the provisions of Republic Act No. 11534, as amended by Republic Act No. 12066, and the Self-Reliant Defense Posture Revitalization Act (RA No. 12024), Registered Business Enterprises (RBEs) engaged in the manufacture of defense material are granted incentives such as Income Tax Holidays, a 5% Special Corporate Income Tax, and VAT exemptions on local purchases and importations of capital equipment and raw materials not locally available. In this case, the subject domestic enterprise, which manufactures firearms and ammunition for government agencies, possesses multiple BOI-registered projects that qualify for these fiscal benefits; however, the application of these facts confirms that the entitlement to incentives for specific projects is contingent upon meeting the 70% export threshold, and the exemption from national internal revenue taxes and VAT on imported materiel is restricted exclusively to items that cannot be sourced within the local market. (BIR RULING NO. OT-207-2025, October 28, 2025) PAYMENTS FOR AIRPORT-RELATED FEES AND RENTALS MADE TO A GOVERNMENT AIRPORT AUTHORITY ARE EXEMPT FROM CREDITABLE WITHHOLDING TAX BECAUSE SUCH REVENUES CONSTITUTE INCOME DERIVED FROM THE EXERCISE OF ESSENTIAL GOVERNMENTAL FUNCTIONS EXCLUDED FROM GROSS INCOME. Pursuant to Section 32 (B) (7) (b) of the National Internal Revenue Code of 1997, as amended, and as supported by Executive Order No. 292, income derived by the Government or its political subdivisions from any public utility or from the exercise of essential governmental functions is excluded from gross income and exempt from taxation. Applying these laws to the facts, the subject international air carrier is not required to withhold taxes on payments made to the national airport authority for landing fees, rentals, and utility charges; while the passage of RA No. 11659 reclassified the airport authority from a “public utility” to a “public service,” it remains a government instrumentality whose primary mandate providing safe and efficient airport facilities—is an essential governmental function rather than a proprietary one, thereby rendering its operational income exempt from income tax and the corresponding creditable withholding tax. (BIR Ruling No. OT-217-2025, November 12, 2025) BIR DEADLINES FROM JANUARY 26 TO JANUARY 31, 2026. A gentle reminder on the following deadlines, as may be applicable: DATE  FILING/SUBMISSION January 29, 2026 e-FILING & PAYMENT (Online/Manual) – BIR Form 1702Q (Quarterly Income Tax Return For Corporations, Partnerships and Other Non-Individual Taxpayers) and Summary Alphalist of Withholding Taxes (SAWT).   Fiscal Quarter ending November 30, 2025 January 30, 2026 SUBMISSION – Proof of e-Filed BIR Form 1702-RT/1702-EX/1702-MX with Audited Financial Statements (AFS), 1709 (if applicable), and Other Attachments through Electronic Audited Financial Statements (eAFS).   Fiscal Year ending September 30, 2025 SUBMISSION – Soft Copies of Inventory List and Schedules stored and saved in DVD-R/USB properly labeled together with a Notarized Sworn Declaration.   Calendar Year ending December 31, 2025 e-SUBMISSION – Quarterly Summary List of Sales/Purchases/Importations by a VAT Registered Taxpayers – eFPS Filers.   For the Quarter ending December 31, 2025 ONLINE REGISTRATION (thru ORUS) – Computerized Books of Accounts and Other Accounting Records.   Calendar Year ending December 31, 2025 January 31, 2026 DISTRIBUTION – BIR Form 2316 (Certificate of Compensation Payment/Tax Withheld – For Compensation Payment With or Without Tax Withheld) to the Employees.   Calendar Year 2025 SUBMISSION – Sworn Declaration of Motels & Other Similar Establishments.   Taxable Year 2025 SUBMISSION – Sworn Statement by Senior Citizens whose Annual Income does not exceed the poverty level as determined by NEDA thru the NSCB.   Taxable Year 2025 SUBMISSION – Annual Information by all Accredited Tax Agents/Practitioners to be submitted to RNAB/RRAB.   Taxable Year 2025 SUBMISSION – Annual Alphabetical List of Professionals/Persons who were issued Professional/Occupational Tax Receipt (PTR/OTR) by LGUs.   Calendar Year ending December 31, 2025 SUBMISSION – Sworn Certification from the International Carrier stating that there is no change in the Domestic Laws of its Home Country Granting Income Tax Exemption to Philippine Carriers.   Calendar Year 2026 for Exemptions issued in 2025 SUBMISSION – Notarized Income Payor/Withholding Agent’s Sworn Declaration with List of Payees Not   Subjected To Withholding Tax.   Calendar Year 2026 SUBMISSION – Contract of Lease and Lessee Information Statement and Other Attachments by Lessors/Sub-Lessors of Commercial Establishments, Buildings or Spaces for Tenants.   2nd Semester of 2025 SUBMISSION – Sworn Statement by every Lessee/Concessionaire/Owner/Operator of Mines or Quarry/Processor of Minerals/Producers or Manufacturers of Mineral Products.   2nd Semester of 2025 e-FILING – BIR Form 1604-C (Annual Information Return of Income Taxes Withheld on Compensation) and/or BIR Form 1604-F (Annual Information Return of Income Payments Subjected to Final Withholding Taxes) and Related Alphalist.   Calendar Year 2025 e-FILING & PAYMENT (Online/Manual) – BIR Form 1601-EQ (Quarterly Remittance Return of Creditable Income Taxes Withheld-Expanded) and Quarterly Alphalist of Payees (QAP) – eFPS & Non-eFPS Filers.   For the Quarter ending December 31, 2025 e-FILING & PAYMENT (Online/Manual) – BIR Form 1601-FQ (Quarterly Remittance Return of Final Income Taxes Withheld) and Quarterly Alphalist of Payees (QAP) – eFPS & Show More January 13 2026 Tax Updates January 12, 2026 COURT OF TAX APPEALS DECISIONS APPEAL OF FDDA TO THE REGIONAL DIRECTOR AND FILING OF MOTION FOR RELIEF TO THE CIR ON THE CIR’S DECISION RENDERS THE ASSESSMENT FINAL AND EXECUTORY. If the protest is denied by the Commissioner of Internal Revenue’s (CIR) duly authorized representative via Final Decision on Disputed Assessment (FDDA), the taxpayer may either: (i) appeal to the CTA within 30 days from date of receipt of the FDDA; or, (ii) elevate his protest through a request for reconsideration to the CIR’s within 30 days from date of receipt of the FDDA. Moreover, if the taxpayer decides to lodge an administrative appeal with the CIR, and the same is denied by the latter, in whole or in part, the taxpayer may appeal to the CTA the CIR’s decision, within 30 days from receipt thereof. Otherwise, the assessment shall become final, executory and demandable.  Thus, where the taxpayer elevated the  FDDA not in the office of commissioner but to the Regional Director, the assessment becomes final. Moreover, where the CIR issued a decision, and instead of appealing to the CTA, the taxpayer filed an Urgent Motion for Relief, the assessment becomes final, and CTA lost jurisdiction. (Permafrost Marketing, Inc. v. CIR, CTA Case No. 10410, July 4, 2025) TAX CREDITS MUST BE CLAIMED IN THE PROPER PERIOD; EXCESS CREDITS WERE DISALLOWED TO PREVENT PREMATURE AND DOUBLE UTILIZATION. Tax credits are allowed only in the taxable period when the related income is earned or received, and may not be prematurely applied or used in a manner that results in double benefit; otherwise, their disallowance is proper. In this case, the BIR disallowed the taxpayer’s claimed creditable withholding taxes because the supporting certificates were dated outside taxable year 2016, and the taxpayer failed to prove that the related income was earned in 2016, thereby justifying the full disallowance. The BIR also deducted the excess minimum corporate income tax and excess creditable taxes carried over to the succeeding period from the taxpayer’s 2016 tax credits to prevent premature and duplicative application of these credits. Verification showed that the excess CWT was actually utilized as credits in later taxable years, confirming that allowing them again against the 2016 deficiency would result in double benefit, while the excess MCIT was not in fact utilized and thus should not have been disallowed. Consequently, the disallowance of CWT and the excess credits carried over was upheld. (Kalayaan Engineering Company Inc. v. Commissioner of Internal Revenue, CTA Case No. 10839, October 29, 2025) 3-YEAR PRESCRIPTION TO ASSESS SHALL APPLY IF 30% THRESHOLD IS NOT BREACHED AND 50% SURCHARGE IS NOT IMPOSED; 3-YEAR PRESCRIPTION TO COLLECT APPLIES  FROM ISSUANCE OF ASSESSMENT AND NOT TOLLED BY REQUEST FOR RECONSIDERATION. Under the law, the prescriptive period for assessment of taxes is three years from the last day to file the return, extendable only if a false or fraudulent return is established with clear evidence, and the period to collect begins upon issuance of the assessment. In this case, there was no substantial under-declaration, overstatement of deductions, or evidence of fraud to invoke the extraordinary 10-year period, and the BIR did not impose the corresponding 50% surcharge. Consequently, the ordinary three-year period applied, making the right to assess deficiency IT, VAT, and EWT for 2013 expire before collection efforts. Moreover, the BIR has three-year period to collect from the issuance of the assessment and tolled when BIR grants a request to reinvestigation. Here, the taxpayer merely requested for reinvestigation. Accordingly, the 3-year prescription applies by the time the BIR enforced collection by filing its Answer. Thus, the Court enjoined the BIR from enforcing collection of the 2013 deficiency taxes. (Noatum Logistics Philippines, Inc. v. Commissioner of Internal Revenue, CTA Case No. 10867, July 30, 2025) ASSESSMENT IS INVALID WHEN WAIVERS ARE NOT ACCEPTED BY THE BIR BEFORE THE ASSESSMENT PERIOD EXPIRES OR ISSUED WITHOUT PROPER AUTHORITY. The law provides that the period to assess taxes is three years, extendable only through validly executed waivers accepted by the BIR and facilitated by officers with proper authority. In this case, five waivers executed by Medicard Philippines, Inc. were defective: four lacked proof of timely BIR acceptance, and four were obtained by a revenue officer without a valid LOA. Consequently, the original three-year prescriptive period for assessing Income Tax, VAT, and EWT for TY 2014 lapsed before the undated Formal Letter of Demand and Assessment Notices were served, rendering them void. As a result, the Court canceled and set aside the assessments. (Medicard Philippines, Inc. v. Commissioner of Internal Revenue, CTA Case No. 10853, October 30, 2025) THE CTA MAY UPHOLD DOUBTFUL VALIDITY OF THE ASSESMMENT EVEN THOUGH BIR DENIES THE OFFER OF COMPROMISE. A compromise may be granted when there exists reasonable doubt as to the validity of the assessment, and while tax assessments are generally presumed correct, such presumption does not apply when the assessment is arbitrary, capricious, or “naked,” meaning it is not anchored on actual facts but merely on presumptions. In this case, the assessment against the taxpayer was premised on alleged “unaccounted sources of cash” derived from discrepancies between its financial statements, VAT returns, and alphalists, which the BIR automatically treated as undeclared income. Consequently, the assessment was based on mere presumptions rather than factual evidence, rendering it not only of doubtful validity but legally defective. (GMA Worldwide (Phils.), Inc. v. Commissioner of Internal Revenue, CTA Case No. 11158, August 1, 2025 RECEIPT OF THE FAN BEFORE THE END OF THE 15-DAY PERIOD TO REPLY TO THE PAN RENDERS THE ASSESSMENT VOID. Taxpayer has 15 days to reply to the PAN. In this case, the records show that the taxpayer received the preliminary assessment notice on March 12, 2015 and was entitled to a full fifteen-day period, or until March 27, 2015, to submit a reply; however, the tax authority prematurely issued the formal letter of demand and final assessment notices on March 26, 2015, or one day before the lapse of the response period, a procedural defect that was expressly admitted by its own witness during trial. Jurisprudence categorically holds that the issuance of a final assessment before the expiration of the taxpayer’s response period constitutes a clear violation of due process, which is not cured by the subsequent filing of a protest or by claims of substantial compliance, and renders the assessment void, incapable of attaining finality, and without any legal basis for collection or compromise(GMA Worldwide (Phils.), Inc. v. Commissioner of Internal Revenue, CTA Case No. 11158, August 1, 2025 ASSESSMENT IS VOID IF THE FAN REITERATED THE FINDINGS IN THE PAN WITHOUT ADDRESSING THE REPLY TO THE PAN. As a legal basis, due process in tax assessment requires that the taxing authority strictly observe the mandatory procedure of fully informing the taxpayer, in writing, of the factual and legal bases of the assessment, and of genuinely considering the taxpayer’s explanations and evidence, with any rejection thereof being supported by stated reasons grounded on facts and law; failure to comply renders the assessment void and without legal effect. In this case, although a preliminary assessment was issued and a protest was timely filed, the subsequent formal letter of demand, final assessment notice, and final decision merely reiterated, almost word for word, the same findings and bases found in the preliminary notice, without addressing, evaluating, or explaining the rejection of the taxpayer’s defenses, thereby showing a patent disregard of the taxpayer’s submissions; moreover, even when the assessment amounts were modified, no reasons or factual bases were provided for such changes. This repetition of findings, coupled with the absence of any articulated consideration of the defenses raised, deprived the taxpayer of administrative due process, rendering the assessment void; in addition, the Court further found that the taxpayer is permanently exempt from income tax under its governing law, so that no deficiency income tax could legally arise in the first place, further nullifying the assessment. (Bukidnon II Electric Cooperative, Inc. v. Commissioner of Internal Revenue, CTA Case No. 11142, October 9, 2025; Imasen Philippine Manufacturing Corporation v. CIR, CTA Case No. 10402 ). ASSESSMENT IS VOID IF A REPLACING REVENUE EXAMINER RECOMMENDED THE PAN BUT LOA NAMING SUCH EXAMINER WAS ISSUED AFTER THE ISSUANCE OF THE PAN. The Tax Code provides that the CIR or duly authorized representatives may examine a taxpayer and issue assessments, and such authority must be expressly granted through a Letter of Authority (LOA); any participation by revenue officers not named in a valid LOA renders the resulting audit or assessment void, as it violates the taxpayer’s right to due process. In this case, although the audit was initially authorized under a valid LOA, a group supervisor who was not named in the LOA participated in supervising and reviewing the audit that led to the issuance of the preliminary assessment notice, and no LOA had been issued for his involvement at that time; consequently, the participation of the unauthorized officer invalidated the assessment and related collection notices, notwithstanding any subsequent LOA or continuation by authorized officers. Accordingly, the assessment and the final decision on the disputed assessment were cancelled and set aside. (O-Healthcare Solution Phil., Inc. v. Commissioner of Internal Revenue, CTA Case No. 10951, July 30, 2025). FAILURE TO FILE A PROTEST OR FILING AN OFFER OF COMPROMISE RENDERS THE ASSESSMENT FINAL AND EXECUTORY; HOWEVER, FAILURE TO INITIATE COLLECTION EFFORTS WITHIN THE PRESCRIBED PERIOD PREVENTS THE BIR FROM COLLECTION. Under the tax laws and implementing regulations, a final assessment becomes final, executory, and demandable when the taxpayer fails to file a valid protest within the prescribed period, fails to submit supporting documents for a protest for reinvestigation, abandons a pending protest, or fails to timely elevate an adverse decision or inaction to the CTA, after which the government is given only a limited period to enforce collection through the modes allowed by law. Applying these rules, the Court held that the deficiency income tax and VAT assessments for taxable years 2006 and 2007 had already become final and executory because the protest filed against the second assessment for 2006 was in substance a mere motion for reconsideration without submission of supporting documents, was later expressly abandoned by the filing of an application for compromise settlement which was treated as an admission of liability, and no protest at all was filed against the 2007 assessment; consequently, while the assessments were already final, the government nonetheless lost its right to collect them because no warrant of distraint and levy, garnishment, or judicial action was initiated within the applicable prescriptive period counted from the taxpayer’s receipt of the final assessment notices, rendering further collection efforts legally untenable, and for the same reasons, the taxpayer was likewise not entitled to any refund of amounts paid pursuant to the compromise application. (Remie R. Talaver v. Hon. Romeo D. Lumagui, in his capacity as Commissioner of Internal Revenue, CTA Case No. 11211, Decision dated 22 August 2025.) INTENT MUST BE ESTABLISHED TO FOR 10-YEAR PRESCRIPTIVE PERIOD TO APPLY. Under the tax laws, the government is generally allowed 3 years which to assess internal revenue taxes, and the use of an extended prescriptive period (10 years) is permitted only in exceptional cases where there is a clear showing that the taxpayer committed false or fraudulent acts with intent to evade tax, which intent must be duly proven. Applying this rule, the Court held that the assessment for taxable year 2009 was already time-barred because the annual income tax return was filed on 15 April 2010, giving the taxing authority only until 15 April 2013 to validly issue an assessment, yet the Final Assessment Notice was issued only on 3 June 2015; at the time the ordinary three-year period lapsed, prevailing jurisprudence already required proof of intent to evade tax before the extended ten-year period could be invoked, and since no such intent was established, the taxing authority could not rely on the longer prescriptive period, rendering the assessment void for having been issued beyond the allowable time. (CTA Case No. 9837, Meridien East Realty & Development Corporation v. CIR, CTA Case No. 9837) Show More COURT OF TAX APPEALS DECISIONS APPEAL OF FDDA TO THE REGIONAL DIRECTOR AND FILING OF MOTION FOR RELIEF TO THE CIR ON THE CIR’S DECISION RENDERS THE ASSESSMENT FINAL AND EXECUTORY. If the protest is denied by the Commissioner of Internal Revenue’s (CIR) duly authorized representative via Final Decision on Disputed Assessment (FDDA), the taxpayer may either: (i) appeal to the CTA within 30 days from date of receipt of the FDDA; or, (ii) elevate his protest through a request for reconsideration to the CIR’s within 30 days from date of receipt of the FDDA. Moreover, if the taxpayer decides to lodge an administrative appeal with the CIR, and the same is denied by the latter, in whole or in part, the taxpayer may appeal to the CTA the CIR’s decision, within 30 days from receipt thereof. Otherwise, the assessment shall become final, executory and demandable.  Thus, where the taxpayer elevated the  FDDA not in the office of commissioner but to the Regional Director, the assessment becomes final. Moreover, where the CIR issued a decision, and instead of appealing to the CTA, the taxpayer filed an Urgent Motion for Relief, the assessment becomes final, and CTA lost jurisdiction. (Permafrost Marketing, Inc. v. CIR, CTA Case No. 10410, July 4, 2025) TAX CREDITS MUST BE CLAIMED IN THE PROPER PERIOD; EXCESS CREDITS WERE DISALLOWED TO PREVENT PREMATURE AND DOUBLE UTILIZATION. Tax credits are allowed only in the taxable period when the related income is earned or received, and may not be prematurely applied or used in a manner that results in double benefit; otherwise, their disallowance is proper. In this case, the BIR disallowed the taxpayer’s claimed creditable withholding taxes because the supporting certificates were dated outside taxable year 2016, and the taxpayer failed to prove that the related income was earned in 2016, thereby justifying the full disallowance. The BIR also deducted the excess minimum corporate income tax and excess creditable taxes carried over to the succeeding period from the taxpayer’s 2016 tax credits to prevent premature and duplicative application of these credits. Verification showed that the excess CWT was actually utilized as credits in later taxable years, confirming that allowing them again against the 2016 deficiency would result in double benefit, while the excess MCIT was not in fact utilized and thus should not have been disallowed. Consequently, the disallowance of CWT and the excess credits carried over was upheld. (Kalayaan Engineering Company Inc. v. Commissioner of Internal Revenue, CTA Case No. 10839, October 29, 2025) 3-YEAR PRESCRIPTION TO ASSESS SHALL APPLY IF 30% THRESHOLD IS NOT BREACHED AND 50% SURCHARGE IS NOT IMPOSED; 3-YEAR PRESCRIPTION TO COLLECT APPLIES  FROM ISSUANCE OF ASSESSMENT AND NOT TOLLED BY REQUEST FOR RECONSIDERATION. Under the law, the prescriptive period for assessment of taxes is three years from the last day to file the return, extendable only if a false or fraudulent return is established with clear evidence, and the period to collect begins upon issuance of the assessment. In this case, there was no substantial under-declaration, overstatement of deductions, or evidence of fraud to invoke the extraordinary 10-year period, and the BIR did not impose the corresponding 50% surcharge. Consequently, the ordinary three-year period applied, making the right to assess deficiency IT, VAT, and EWT for 2013 expire before collection efforts. Moreover, the BIR has three-year period to collect from the issuance of the assessment and tolled when BIR grants a request to reinvestigation. Here, the taxpayer merely requested for reinvestigation. Accordingly, the 3-year prescription applies by the time the BIR enforced collection by filing its Answer. Thus, the Court enjoined the BIR from enforcing collection of the 2013 deficiency taxes. (Noatum Logistics Philippines, Inc. v. Commissioner of Internal Revenue, CTA Case No. 10867, July 30, 2025) ASSESSMENT IS INVALID WHEN WAIVERS ARE NOT ACCEPTED BY THE BIR BEFORE THE ASSESSMENT PERIOD EXPIRES OR ISSUED WITHOUT PROPER AUTHORITY. The law provides that the period to assess taxes is three years, extendable only through validly executed waivers accepted by the BIR and facilitated by officers with proper authority. In this case, five waivers executed by Medicard Philippines, Inc. were defective: four lacked proof of timely BIR acceptance, and four were obtained by a revenue officer without a valid LOA. Consequently, the original three-year prescriptive period for assessing Income Tax, VAT, and EWT for TY 2014 lapsed before the undated Formal Letter of Demand and Assessment Notices were served, rendering them void. As a result, the Court canceled and set aside the assessments. (Medicard Philippines, Inc. v. Commissioner of Internal Revenue, CTA Case No. 10853, October 30, 2025) THE CTA MAY UPHOLD DOUBTFUL VALIDITY OF THE ASSESMMENT EVEN THOUGH BIR DENIES THE OFFER OF COMPROMISE. A compromise may be granted when there exists reasonable doubt as to the validity of the assessment, and while tax assessments are generally presumed correct, such presumption does not apply when the assessment is arbitrary, capricious, or “naked,” meaning it is not anchored on actual facts but merely on presumptions. In this case, the assessment against the taxpayer was premised on alleged “unaccounted sources of cash” derived from discrepancies between its financial statements, VAT returns, and alphalists, which the BIR automatically treated as undeclared income. Consequently, the assessment was based on mere presumptions rather than factual evidence, rendering it not only of doubtful validity but legally defective. (GMA Worldwide (Phils.), Inc. v. Commissioner of Internal Revenue, CTA Case No. 11158, August 1, 2025 RECEIPT OF THE FAN BEFORE THE END OF THE 15-DAY PERIOD TO REPLY TO THE PAN RENDERS THE ASSESSMENT VOID. Taxpayer has 15 days to reply to the PAN. In this case, the records show that the taxpayer received the preliminary assessment notice on March 12, 2015 and was entitled to a full fifteen-day period, or until March 27, 2015, to submit a reply; however, the tax authority prematurely issued the formal letter of demand and final assessment notices on March 26, 2015, or one day before the lapse of the response period, a procedural defect that was expressly admitted by its own witness during trial. Jurisprudence categorically holds that the issuance of a final assessment before the expiration of the taxpayer’s response period constitutes a clear violation of due process, which is not cured by the subsequent filing of a protest or by claims of substantial compliance, and renders the assessment void, incapable of attaining finality, and without any legal basis for collection or compromise(GMA Worldwide (Phils.), Inc. v. Commissioner of Internal Revenue, CTA Case No. 11158, August 1, 2025 ASSESSMENT IS VOID IF THE FAN REITERATED THE FINDINGS IN THE PAN WITHOUT ADDRESSING THE REPLY TO THE PAN. As a legal basis, due process in tax assessment requires that the taxing authority strictly observe the mandatory procedure of fully informing the taxpayer, in writing, of the factual and legal bases of the assessment, and of genuinely considering the taxpayer’s explanations and evidence, with any rejection thereof being supported by stated reasons grounded on facts and law; failure to comply renders the assessment void and without legal effect. In this case, although a preliminary assessment was issued and a protest was timely filed, the subsequent formal letter of demand, final assessment notice, and final decision merely reiterated, almost word for word, the same findings and bases found in the preliminary notice, without addressing, evaluating, or explaining the rejection of the taxpayer’s defenses, thereby showing a patent disregard of the taxpayer’s submissions; moreover, even when the assessment amounts were modified, no reasons or factual bases were provided for such changes. This repetition of findings, coupled with the absence of any articulated consideration of the defenses raised, deprived the taxpayer of administrative due process, rendering the assessment void; in addition, the Court further found that the taxpayer is permanently exempt from income tax under its governing law, so that no deficiency income tax could legally arise in the first place, further nullifying the assessment. (Bukidnon II Electric Cooperative, Inc. v. Commissioner of Internal Revenue, CTA Case No. 11142, October 9, 2025; Imasen Philippine Manufacturing Corporation v. CIR, CTA Case No. 10402 ). ASSESSMENT IS VOID IF A REPLACING REVENUE EXAMINER RECOMMENDED THE PAN BUT LOA NAMING SUCH EXAMINER WAS ISSUED AFTER THE ISSUANCE OF THE PAN. The Tax Code provides that the CIR or duly authorized representatives may examine a taxpayer and issue assessments, and such authority must be expressly granted through a Letter of Authority (LOA); any participation by revenue officers not named in a valid LOA renders the resulting audit or assessment void, as it violates the taxpayer’s right to due process. In this case, although the audit was initially authorized under a valid LOA, a group supervisor who was not named in the LOA participated in supervising and reviewing the audit that led to the issuance of the preliminary assessment notice, and no LOA had been issued for his involvement at that time; consequently, the participation of the unauthorized officer invalidated the assessment and related collection notices, notwithstanding any subsequent LOA or continuation by authorized officers. Accordingly, the assessment and the final decision on the disputed assessment were cancelled and set aside. (O-Healthcare Solution Phil., Inc. v. Commissioner of Internal Revenue, CTA Case No. 10951, July 30, 2025). FAILURE TO FILE A PROTEST OR FILING AN OFFER OF COMPROMISE RENDERS THE ASSESSMENT FINAL AND EXECUTORY; HOWEVER, FAILURE TO INITIATE COLLECTION EFFORTS WITHIN THE PRESCRIBED PERIOD PREVENTS THE BIR FROM COLLECTION. Under the tax laws and implementing regulations, a final assessment becomes final, executory, and demandable when the taxpayer fails to file a valid protest within the prescribed period, fails to submit supporting documents for a protest for reinvestigation, abandons a pending protest, or fails to timely elevate an adverse decision or inaction to the CTA, after which the government is given only a limited period to enforce collection through the modes allowed by law. Applying these rules, the Court held that the deficiency income tax and VAT assessments for taxable years 2006 and 2007 had already become final and executory because the protest filed against the second assessment for 2006 was in substance a mere motion for reconsideration without submission of supporting documents, was later expressly abandoned by the filing of an application for compromise settlement which was treated as an admission of liability, and no protest at all was filed against the 2007 assessment; consequently, while the assessments were already final, the government nonetheless lost its right to collect them because no warrant of distraint and levy, garnishment, or judicial action was initiated within the applicable prescriptive period counted from the taxpayer’s receipt of the final assessment notices, rendering further collection efforts legally untenable, and for the same reasons, the taxpayer was likewise not entitled to any refund of amounts paid pursuant to the compromise application. (Remie R. Talaver v. Hon. Romeo D. Lumagui, in his capacity as Commissioner of Internal Revenue, CTA Case No. 11211, Decision dated 22 August 2025.) INTENT MUST BE ESTABLISHED TO FOR 10-YEAR PRESCRIPTIVE PERIOD TO APPLY. Under the tax laws, the government is generally allowed 3 years which to assess internal revenue taxes, and the use of an extended prescriptive period (10 years) is permitted only in exceptional cases where there is a clear showing that the taxpayer committed false or fraudulent acts with intent to evade tax, which intent must be duly proven. Applying this rule, the Court held that the assessment for taxable year 2009 was already time-barred because the annual income tax return was filed on 15 April 2010, giving the taxing authority only until 15 April 2013 to validly issue an assessment, yet the Final Assessment Notice was issued only on 3 June 2015; at the time the ordinary three-year period lapsed, prevailing jurisprudence already required proof of intent to evade tax before the extended ten-year period could be invoked, and since no such intent was established, the taxing authority could not rely on the longer prescriptive period, rendering the assessment void for having been issued beyond the allowable time. (CTA Case No. 9837, Meridien East Realty & Development Corporation v. CIR, CTA Case No. 9837) Show More 1 2 3 … 23 Next » Articles February 23, 2026 Tax Updates February 12 2026 Tax Update SAVE ON TAX IF YOU HAVE 70% EXPORT SALES! January 29 2026 Tax Update January 19 2026 Tax Updates January 13 2026 Tax Updates Decemeber 22 2025 Tax Updates (Update) Decemeber 5 2025 Tax Updates November 28 2025 Tax Updates October 23 2025 Tax Updates Archives Archives Recent Articles Loading... February 23, 2026 Tax Updates February 23, 2026 Read More February 12 2026 Tax Update February 12, 2026 Read More SAVE ON TAX IF YOU HAVE 70% EXPORT SALES! February 5, 2026 Read More 1 2 … 29 Court of Tax Appeals Decisions Articles Loading... June 06 2025 Tax Updates June 5, 2025 May 9 2025 Tax Updates May 9, 2025 OCTOBER TO DECEMBER 2024 CTA DECISIONS April 22, 2025 Security and Exchange Commission Articles Loading... SEC Updates January 25-29 2023 January 23, 2023 SEC Updates December 5-11 2022 December 19, 2022 GUIDELINES ON CORPORATE DISSOLUTION UNDER SECTIONS 134, 136 AND 138 OF THE REVISED CORPORATION CODE. March 16, 2022 Bureau of Internal Revenue Articles Loading... Ease of Paying Taxes Act Revenue Regulations May 7, 2024 BIR Updates March 18, 2024 May 7, 2024 BUREAU OF INTERNAL REVENUE UPDATES March 11, 2024 Recent Articles Loading... February 23, 2026 Tax Updates February 23, 2026 Read More February 12 2026 Tax Update February 12, 2026 Read More SAVE ON TAX IF YOU HAVE 70% EXPORT SALES! February 5, 2026 Read More January 29 2026 Tax Update January 29, 2026 Read More January 19 2026 Tax Updates January 19, 2026 Read More End of content No more pages to load 1 2 3 … 27