COURT OF TAX APPEALS DECISIONS Receipt of Preliminary Assessment Notice (PAN) by a person who is not an employee renders the assessment void. According to Revenue Regulations No. 12-99, Section 3.1.6, as amended,, tax notices such as the PAN and Formal Letter of Demand (FLD) must be served personally. If
LETTER OF AUTHORITY A LETTER OF AUTHORITY (LOA) MAY COVER MORE THAN ONE TAXABLE YEAR. RMO 43-1990 provides that if the audit of the taxpayer shall include more than one taxable period, the other periods or years shall be specifically included in the LOA. In Commissioner of Internal Revenue (CIR)
ON VAT AND PERCENTAGE TAX PROVISIONS (RR No. 3-2024) The EOPT adopts the accrual basis of recognizing sales for both sales of goods and services, including transactions to government or any of its political subdivisions, instrumentalities or agencies, and government-owned or -controlled corporations (GOCCs). All references to “gross selling price”, “gross value in
THE BIR CLARIFIES THE TREATMENT OF FOREIGN CURRENCY TRANSACTIONS FOR FINANCIAL REPORTING AND INTERNAL REVENUE TAX PURPOSES. RMC No. 12-2024, January 22, 2024 Particulars PFRS Current Tax Treatment Initial measurement of foreign currency transactions Recorded in functional currency using spot rate of exchange at transaction date Philippine Peso
SALE OR IMPORTATION OF COVID-19 EQUIPMENT AND DRUGS ARE SUBJECT TO VAT STARTING JANUARY 1, 2024. RMC No. 7-2024, January 11, 2024 The BIR reverses the Value-Added Tax exemption of transactions specified under Section 109 (BB) of the National Internal Revenue Code (Tax Code) of 1997, as amended. Sale or importation
NEW PRICE THRESHOLD FOR THE SALE OF HOUSE AND LOT AND OTHER RESIDENTIAL DWELLINGS FOR VAT-EXEMPT PURPOSES IS P3,600,000 RR NO. 1-2024, JANUARY15, 2024 INCOME PAYMENTS MADE BY JV TO SUPPLIERS ARE SUBJECT TO WITHHOLDING TAX (1%/2%); SHARE OF CO-VENTURE FROM JV NOT TAXABLE AS CORPORATION IS SUBJECT TO
DIGEST OF 2023 SUPREME COURT TAX DECISIONS ASSOCIATION DUES, MEMBERSHIP FEES, AND OTHER ASSESSMENTS/CHARGES ARE NOT SUBJECT TO INCOME TAX, VALUE- ADDED TAX AND WITHHOLDING TAX. They only constitute contributions to and/or replenishment of the funds for the maintenance and operations of the facilities offered by recreational clubs to their
GAIN FROM MANDATED FINANCIAL RESTRUCTURING IS NOT SUBJECT TO INCOME TAX. Section 19 of R.A. No. 10142 states that taxes and fees due to the national government imposed upon the issuance of the commencement order and until the approval of the rehabilitation plan or dismissal of the petition, whichever is
TAX ASSESSMENTS A SEPARATE LETTER OF AUTHORITY (LOA) IS NEEDED FOR THE EXAMINATION OF OTHER TAXPAYERS. An LOA defines and limits the scope of audit and examination that revenue officers can undertake with respect to a particular taxpayer’s books of accounts and other accounting records for purposes of determining the tax
TAX ASSESSMENTS THE LAPSE OF THE AUDIT PERIOD DOES NOT RENDER THE SUBJECT LOA INVALID AND WILL NOT HAVE THE EFFECT OF REVOKING THE AUTHORITY GIVEN THEREUNDER TO THE CONCERNED RO. The revalidation of LOAs which should be done “for failure of the revenue officials to complete the audit within
