...uring focus on the central issue and its straightforward application. National Internal Revenue Code of 1997 (as amended) – definitions and inclusions of gross income (prizes/winnings and compensation).
Citations: National Internal Revenue Code of 1997 (as amended) – definitions and inclusions of gross income (prizes/winnings and compensation).
A NovaTech Industries, Inc., a corporate taxpayer subject to the National Internal Revenue Code, receives a Final Assessment Notice (FAN) for 2024 indicating a corporate income tax deficiency of ₱3,400,000 arising from a...
Citations: National Internal Revenue Code of 1997, as amended (NIRC)
...it to a realistic post-payment remedy path. Rule 58, Rules of Court, National Internal Revenue Code (NIRC), Se...
Citations: Rule 58, Rules of Court, National Internal Revenue Code (NIRC), Sec. 204 (Refunds) and related provisions
...deficiency VAT for 2021 in the amount of PHP 4,500,000. The Bureau of Internal Revenue (BIR) offers to compromise the civil liability: payment of PHP 2,700,000 within 20 days in full settlement, with penalties and intere...
Citations: National Internal Revenue Code (NIRC) Sec. 204 (Compromise of Civil Liabilities), BIR rules/regulations implementing compromise (general references to NIRCSec. 204 guidance)
...practical computation framework without drifting into related topics. National Internal Revenue Code of 1997, as amended (NIRC), NIRC provisions governing deficiency interest and delinquency interest (civil penalties und...
Citations: National Internal Revenue Code of 1997, as amended (NIRC), NIRC provisions governing deficiency interest and delinquency interest (civil penalties under the tax code)
...to a concrete situation, without drifting into unrelated tax topics. National Internal Revenue Code of 1997, as amended (NIRC)
Citations: National Internal Revenue Code of 1997, as amended (NIRC)
...test. On November 15, 2023, the BIR filed an Action for Collection of National Taxes (ACNT) in the Regional Trial Court to recover the deficiency, interest, and penalties. ABC contends that the FAN is invalid for lack of...
Citations: National Internal Revenue Code of the Philippines (NIRC) provisions on assessment, protests, and collection., Court of Tax Appeals Act/authority and its role in reviewing BIR assessments., BIR procedures for protest, final assessment, and collection actions.
...protest. On March 15, 2025, the BIR filed an Action for Collection of National Taxes (ACNT) in the Regional Trial Court to recover the deficiency, interest, and penalties. FreshTech contends that the FAN is invalid for l...
Citations: National Internal Revenue Code (NIRC) (as amended) — governing assessments, protests, and collection; finality of FAN after denial or expiration of protest period., BIR regulations and procedures on protests, Final Assessment Notices, and collection remedies (e.g., Revenue Regulations and RMCs governing protest and ACNT)., Court of Tax Appeals decisions in relation to protest/CTA versus ACNT in the administration of national taxes
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 p...
Citations: Rule 65, Rules of Court (injunctions, TROs), National Internal Revenue Code (NIRC) context for tax collection under protest
...ncy income tax for 2023 in the amount of PHP 8,000,000. The Bureau of Internal Revenue (BIR) offers to compromise the civil liability: payment of PHP 4,500,000 within 15 days in full settlement, with penalties and intere...
Citations: National Internal Revenue Code (NIRC) provisions on compromise of civil tax liabilities; BIR issuances interpreting compromise (e.g., guidance on settlement and waivers); Tax Amnesty statutes and related jurisprudence; Court of Tax Appeals and Philippine Supreme Court discussions on the enforceability of compromises.
...otest. On November 2, 2025, the BIR filed an Action for Collection of National Taxes (ACNT) in the Regional Trial Court to recover the deficiency, interest, and penalties. Lumina Tech contends that the FAN is invalid for...
Citations: National Internal Revenue Code (NIRC) provisions on protest, finality, and collection, Court of Tax Appeals rulings on protest versus collection actions, BIR guidelines on Final Assessment Notices and collection procedures
...a VAT-registered taxpayer, is assessed PHP 7,900,000 by the Bureau of Internal Revenue (BIR) for a deficiency in value-added tax for calendar year 2024. The BIR issues a collection order pending judgment on the assessmen...
Citations: Rules of Court, Rule 58 (Temporary Restraining Orders and Preliminary Injunctions)., National Internal Revenue Code (NIRC) provisions governing refunds/recourse after erroneous tax assessments (e.g., refund/overpayment mechanisms).
...tion, a domestic corporation, receives two notices from the Bureau of Internal Revenue: (i) a Notice of Deficiency Tax for the 2023 taxable year, and (ii) a separate Notice of Surcharge for failure to pay the deficiency...
Citations: National Internal Revenue Code of 1997, as amended (NIRC), BIR rulings/regulations on surcharge, Court of Tax Appeals decisions interpreting surcharge
...otest. On February 5, 2025, the BIR filed an Action for Collection of National Taxes (ACNT) in the Regional Trial Court to recover the deficiency, interest, and penalties. Pinnacle contends that the FAN is invalid for la...
Citations: National Internal Revenue Code (as amended), Court of Tax Appeals Act (Republic Act No. 1125), Provisions on protest and collection procedures under the NIRC, Court of Tax Appeals decisions interpreting protest vs. collection remedies (CTA as forum for merits)
...ncy income tax for 2020 in the amount of PHP 1,500,000. The Bureau of Internal Revenue (BIR) offers to compromise the civil liability under applicable law: payment of PHP 900,000 within 15 days in full satisfaction, with...
Citations: National Internal Revenue Code (NIRC), Sec. 204 (Compromise and Abatements)
...IR denied the protest. The BIR then filed an Action for Collection of National Taxes in the Regional Trial Court to recover the deficiency plus interest and penalties. XYZ contends that the FAN is invalid for lack of pro...
Citations: National Internal Revenue Code (NIRC) of the Philippines, Court of Tax Appeals Act (R.A. No. 1125), Constitution of the Philippines, Art. VI, Sec. 28(1)
Jade Electronics, Inc., a corporation subject to corporate income tax, receives an NIRC assessment dated January 20, 2025, for deficiency in corporate income tax for the year 2023 in the amount of PHP 18,000,000, with...
Citations: National Internal Revenue Code of 1997, as amended
...nd how payments affect each, plus the avenues for challenging either. National Internal Revenue Code of 1997 (...
Citations: National Internal Revenue Code of 1997 (as amended), Court decisions interpreting deficiency and delinquency under the NIRC
Aureo Holdings, Inc., a corporation subject to corporate income tax, receives an NIRC assessment dated August 12, 2024, for deficiency in corporate income tax for the year 2023 in the amount of PHP 40,000,000, with pa...
Citations: National Internal Revenue Code of 1997, as amended
BrightArc Management, Inc., a corporation subject to corporate income tax, receives an NIRC assessment dated August 20, 2025, for deficiency in corporate income tax for the year 2024 in the amount of PHP 18,000,000, w...
Citations: National Internal Revenue Code of 1997 (as amended), BIR guidelines on tax remedies under the NIRC, Court of Tax Appeals decisions interpreting deficiency and delinquency (as applicable)
...a resident Filipino, is employed as a management consultant by a multinational firm. During the year, she earned a total compensation of ₱1,900,000 for services rendered; 55% of the services were performed in the Philipp...
Citations: National Internal Revenue Code of 1997, as amended (NIRC); sources of income concept (income from sources within the Philippines) and residence-based taxation rules.
...esident Filipino digital marketing consultant, is employed by an international firm. During the year, he earned total compensation of ₱2,100,000 for services performed, with 60% of the services performed in the Philippin...
Citations: National Internal Revenue Code of 1997, as amended (NIRC)
...ues for challenging the assessment, all within the scope of the NIRC. National Internal Revenue...
Citations: National Internal Revenue Code of 1997, as amended, BIR rules/regulations on deficiency assessments, delinquency, and remedies (including protest and appeal processes)
Sunpeak Tech Corporation, a corporation subject to corporate income tax, receives an NIRC assessment dated January 15, 2025, for deficiency in corporate income tax for the year 2023 in the amount of PHP 18,000,000, wi...
Citations: National Internal Revenue Code of 1997, as amended.
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