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SyCipLaw’s Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S.) for April which covers the following tax issues:

  1. May a revenue officer (“RO”) conduct an examination of a taxpayer’s accounts based on a Letter of Authority (“LOA”) that contains the name of another RO and a Memorandum Referral signed by the Revenue District Officer? 
     
  2. May an isolated transaction of a corporation be subject to value-added tax (“VAT”)?
     
  3. In assailing a tax assessment, can a taxpayer who receives a Warrant of Distraint and/or Levy, instead of a Final Decision on Disputed Assessment, already elevate the case to the CTA?
     
  4. Is a PEZA-registered entity enjoying a preferential tax rate of 5% on gross income in lieu of national and local taxes liable for documentary stamp tax (“DST”)?
     
  5. Is a consularized Letters Patent of Amalgamation sufficient to prove that a foreign corporation is not doing business in the Philippines, for purposes of qualifying for value-added tax zero-rating under Section 108(B)(2) of the NIRC?
     
  6. What is the process for filing the annual income tax return for calendar year 2022 and the payment of the corresponding taxes?
     
  7. What is the scope of the current guidelines and procedures under Revenue Memorandum Order (“RMO”) No. 10-2013, as amended by RMO No. 8-2014 governing the BIR’s issuance and enforcement of Subpoena Duces Tecum (“SDT”)? 
     
  8. Is there data sharing between the SEC and the BIR?
     
  9. What are the amendments to RMO No. 6-2023 in relation to the policies, guidelines, and procedures for the BIR’s audit program?
     
  10. When is the deadline for the bond-free period for registered business enterprises (“RBEs”) in the Information Technology-Business Process Management (“IT-BPM”) sector that transferred their registration to the Board of Investments (“BOI”) to move equipment and other assets outside the economic zone or freeport zone?
     
  11. In a tax-free exchange pursuant to a merger, are the unrestricted retained earnings of the absorbed corporation subject to final withholding tax on dividends?

Please read the full text here or via this link. 

WRITTEN BY

For further information, please contact:

Carina C. Laforteza – SyCipLaw,
cclaforteza@syciplaw.com

Carina C. Laforteza – SyCipLaw

Ms. Laforteza, an expert in Philippine taxation and corporate law, with extensive experience in tax structuring, litigation, and mergers. She's a CPA and lecturer at UP College of Law.

Ms. Laforteza is an expert on Philippine taxation and her tax work ranges from tax structuring for corporations, individuals, estates, tax compliance, as well as tax-related litigation and arbitration, including safeguard measures investigations. She is also an experienced corporate lawyer and has handled mergers, acquisitions and divestments (including transaction structuring, documentation and due diligence), as well as financing work, where she has acted for both lenders and borrowers.

She is a professorial lecturer in taxation at the University of the Philippines – College of Law and was a bar examiner in Taxation in the 2020/2021 Bar Examination given by the Philippine Supreme Court. 

Ms. Laforteza is also a certified public accountant.

She has been ranked by Chambers Asia Pacific as a Pacific since 2010.

Link to corporate profile: https://syciplaw.com/lawyers/partners/CCLaforteza

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