Flashcards Studio

DeltaBuild Inc. owes deficiency VAT for 2019 in the amount of PHP 4,000,000. The Bureau of Internal Revenue (BIR) offers to compromise the civil liability: payment of PHP 2,500,000 within 20 days in full settlement, with penalties and interest waived. DeltaBuild accepts and pays PHP 2,500,000. Six months later, a nationwide tax amnesty law is enacted providing a waiver of penalties and interest on all outstanding liabilities if the principal tax is paid within the amnesty period. DeltaBuild now seeks to avail of the amnesty to erase the remaining PHP 1,500,000. (a) Identify the controlling doctrine governing compromise of civil tax liabilities and the effect of a valid compromise on the liability, including penalties and interest. (b) Distinguish how a tax amnesty operates relative to a valid compromise, and whether DeltaBuild can simultaneously or subsequently benefit from the amnesty for the same liability. (c) If the compromise is challenged as lacking formality or authority, what remedy is available to the government and/or the taxpayer, and what is the consequence if the compromise is valid and performed?