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Question
In a domestic cross-border transfer-pricing dispute before the Court of Tax Appeals, Atty. Chen, a general practitioner, accepts representation of a multinational client seeking relief from penalties under the national tax regime for transfer-pricing adjustments. Chen has no formal training in international taxation or cross-border regulatory compliance. He delegates the essential research and drafting to a junior associate with minimal experience and does not retain or consult a licensed international tax specialist in the Philippines. The filings misinterpret treaty provisions and transfer-pricing rules, resulting in penalties and delays for the client. (a) Identify the CPRA provisions on the General Duty of Competence (Canon IV, Sec. 1) and the obligation stated in Sec. 2, first sentence. (b) Does Chen’s conduct violate these provisions? Distinguish whether competence requires subject-matter mastery, reasonable preparation, and/or association with competent counsel. (c) What remedial actions or sanctions may apply, and what steps should Chen take going forward?