SyCipLaw’s Tax Department has prepared an international edition of its Tax Issues and Practical Solutions (T.I.P.S.) for the first quarter of 2024.
The SyCipLaw T.I.P.S – International Edition covers the following tax issues:
- Are informal settlement agreements between the Commissioner of Internal Revenue and the taxpayer valid and binding?
- While a tax case is pending in court, may the CIR and the taxpayer enter into a compromise agreement and request for judicial approval thereof?
- May a corporation file a claim for a tax refund if it paid final withholding taxes on dividends, which were erroneously declared and paid?
- Does the Court of Tax Appeals have jurisdiction over a petition for review questioning a Final Notice Before Seizure issued by the Bureau of Internal Revenue?
- Are all international service provisions or cross-border service agreements rendered by non-resident foreign corporations (“NRFCs“) automatically subject to income tax and VAT pursuant to Revenue Memorandum Circular (“RMC“) No. 5-2024?