SyCipLaw’s Tax Department has prepared a mega edition of its Tax Issues and Practical Solutions (T.I.P.S.) for September to November 2025.
Please read the full text here or via this link.
The SyCipLaw T.I.P.S. for September-November 2025 covers the following tax issues:
- May the Bureau of Internal Revenue summarily collect an alleged tax liability through the administrative remedies of distraint, levy, and garnishment without first issuing a valid formal assessment, particularly when the taxpayer’s return indicates no tax due?
- Does the Discovery Rule, which computes the prescription of a criminal offense from the date of discovery, apply to all criminal offenses punishable under the Tax Code?
- Is VAT zero-rating on local purchases of goods and services exclusively available to Registered Export Enterprises?
- Is an offshore loan agreement subject to documentary stamp tax?
- Does the CIR’s accreditation of tax agents and practitioners conflict with the mandate of the Professional Regulatory Board of Accountancy?
- Is a taxpayer liable to pay the local business taxes indicated in a Statement of Account issued by a local government unit for business permit renewal purposes?
- Is a taxpayer liable to pay local business taxes computed based on the Presumptive Income Level Assessment Approach, which is not expressly authorized under a local tax ordinance?
- When is the reckoning point of the 30-day period to appeal to the CTA from the CIR’s denial of a VAT refund claim, when the CIR’s written denial was received by a taxpayer beyond the 90-day period for the CIR to act on the refund claim?
- Did the TRAIN Law repeal the “deemed denial rule” and remove the taxpayer’s remedy to appeal the CIR’s inaction on a VAT refund claim within the lapse of 30 days from said inaction?
- What are the updated guidelines on determining whether a business expense is considered ordinary and necessary for purposes of deduction from gross income?
- How can a taxpayer request a Certified True Copy of the Commissioner of Internal Revenue’s decision on an administrative appeal against a Final Decision on Disputed Assessment and on the denial of the claims for refund of value-added tax and excise tax?
- What automobiles are exempt from excise tax?
- How is the sale, exchange, or other disposition of shares of stock and other securities of a domestic corporation listed and traded on a foreign stock exchange taxed?
- How do the transitory rules apply to financial instruments issued or transaction prior to July 1, 2025 under the implementing rules on passive income taxation under Republic Act No. 12214 or the Capital Markets Efficiency Promotion Act?
- How can employers avail the additional deductions under the Personal Equity and Retirement Account?
- What is the creditable withholding tax rate on the income payments of top withholding agents to the manufacturers and direct importers of motor vehicles in Completely Built Units or Semi-Knockdown units?
- Is a withholding agent required to deduct back-withholding taxes that it failed to withhold if the supplier already paid the appropriate tax?
- Is the income received for the supply of technical services for data preparation, systems evaluation, project management, and final checking of the systems after evaluation rendered by a non-resident foreign corporation to a domestic corporation subject to tax in the Philippines?
- Are soft/electronic copies of BIR Form No. 2307 with e-signatures sufficient for claims for tax refund/credit certificates and tax audits with the BIR?
- What is Republic Act No. 12253 and its impact to the mining industry?
This bulletin was prepared by Catherina M. Fernandez, special counsel and a member of SyCipLaw’s Tax Department, with the assistance of Associates Aila Mae B. Berdin, Joanna Marie P. Reyes, Marie Antoinette D. Rodriguez, Robert M. Sanders, Jr., Maria Luisa J. Sebastian, Alithea C. Soriano, and Megan Audrey G. Venturanza.
