Flashcards Studio

GlobeTech International, Inc., a VAT-registered taxpayer, is assessed PHP 10,400,000 by the Bureau of Internal Revenue (BIR) for a deficiency in value-added tax for calendar year 2021. The BIR issues a collection order pending judgment on the assessment. GlobeTech petitions for a temporary restraining order to prevent tax collection while the dispute is reviewed. The trial court denies the TRO. GlobeTech pays the PHP 10,400,000 under protest and later files a separate action for refund and for a declaration that the assessment is invalid. (a) Identify the controlling doctrine governing whether an injunction may restrain tax collection. (b) Distinguish this doctrine from the ordinary rule on injunctions. (c) Apply the doctrine to GlobeTech’s facts: should the injunction have been granted? what is the proper remedy, and what outcome can GlobeTech expect in the refund action?