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Congress enacts the Digital Market Tax Act (DMTA) authorizing the Secretary of Finance to issue regulations necessary...

...cannot enforce a regulation that creates a new obligation beyond the National Internal Revenue Code (NIRC). (a) Identify the controlling doctrinal issue governing the validity of RR DMTA-01. (b) Distinguish the standard...

Citations: 1987 Constitution, Article VI, Section 28 (Power to Tax), National Internal Revenue Code (NIRC), Sec. 6 (Regulations), NTRC/DMTA framework (as introduced in the hypothetical)

a) State the controlling doctrine governing when the CTA En Banc may review a CTA Division decision. b) Explain the p...

...Banc may review a CTA Division decision. b) Explain the proper scope of En Banc review, including whether it may reweigh findings of fact and what issues it may resolve, with respect to questions of law versus fact. c)...

Citations: National Internal Revenue Code (NIRC), Section 106(A) on VAT zero-rating for export of services, Rules of Court, Rule 65 (certiorari), Revised Rules on Court of Tax Appeals (En Banc review)

Sunrise City Ordinance No. 2026-08 imposes a 3% gross receipts tax on any platform that provides targeted digital adv...

...ling rule between local taxation of nonresident digital platforms and national taxation of Philippine-source income. (c) Apply the doctrine to the facts and determine whether the ordinance is constitutional. If not, expl...

Citations: 1987 Constitution, Article VI, Section 28 (Local government taxation and limits), Republic Act No. 7160 (Local Government Code of 1991), National Internal Revenue Code (NIRC) of 1997 (as amended)

Congress enacts a Digital Economy Tax Act (DETA) authorizing the Secretary of Finance to issue regulations necessary...

...cannot enforce a regulation that creates a new obligation beyond the National Internal Revenue Code (NIRC). (a) Identify the controlling doctrinal issue governing the validity of RR No. 2024-01. (b) Distinguish the stan...

Citations: National Internal Revenue Code of the Philippines (NIRC) (as amended), Revenue Regulations (as implementing rules under the NIRC), Ultra vires doctrine (administrative law principle)

Textronics Philippines, Inc. receives a Notice of Deficiency for deficiency VAT for 2024 dated February 12, 2025. It...

Textronics Philippines, Inc. receives a Notice of Deficiency for deficiency VAT for 2024 dated February 12, 2025. It timely files a protest within 30 days from receipt. On May 31, 2025, the Commissioner issues a Decision...

Citations: National Internal Revenue Code of 1997, as amended (NIRC), Republic Act No. 1125 (Court of Tax Appeals Act), Court of Tax Appeals Rules of Procedure (as applicable to review of protest decisions)

BluePeak Technology, Inc. receives a Notice of Assessment for deficiency VAT for 2023 dated January 15, 2024. It time...

...Parkway, but the BIR records were not updated. On April 20, 2024, the internal mailroom locates the decision and forwards a copy to BluePeak’s Corporate Secretary. BluePeak files a Petition for Review with the Court of T...

Citations: National Internal Revenue Code of 1997, as amended (NIRC)., Court of Tax Appeals Act (Republic Act No. 1125, as amended)., Jurisprudence interpreting petition-for-review timelines and receipt-based review by the CTA (protest scope and new issues).

Citywide Tech Services, Inc., a domestic corporation, receives a Notice of Assessment for deficiency corporate income...

...cedural rule governing Administrative Remedies in Philippine tax law. National Internal Revenue C...

Citations: National Internal Revenue Code of 1997, as amended (NIRC), Court of Tax Appeals Act (as applied to protest and review procedures)

Congress enacts the Digital Advertising Tax Act (DATA), authorizing the Secretary of Finance to issue regulations nec...

...cannot enforce a regulation that creates a new obligation beyond the National Internal Revenue Code (NIRC). (a) Identify the controlling doctrinal issue governing the validity of RR DATA-01. (b) Distinguish the standard...

Citations: National Internal Revenue Code (NIRC), Republic Act No. 8424 (as amended), Revenue Regulations and Circulars issued by the Secretary of Finance/CIR governing tax administration, Philippine Supreme Court jurisprudence interpreting the binding effect and limits of Revenue Regulations

Congress enacts the Digital Platform Tax Act (DPTA) authorizing the Secretary of Finance to issue regulations necessa...

...cannot enforce a regulation that creates a new obligation beyond the National Internal Revenue Code (NIRC). (a) Identify the controlling doctrinal issue governing the validity of RR No. DPTA-01. (b) Distinguish the stan...

Citations: Republic Act No. 8424 (National Internal Revenue Code), Constitution, Article VI on taxation and powers of Congress, General principles on Revenue Regulations as implementing rules under the NIRC

Congress enacts the Green Tech Tax Act (GTTA), authorizing the Secretary of Finance to issue regulations necessary to...

...cannot enforce a regulation that creates a new obligation beyond the National Internal Revenue Code (NIRC). (a) Identify the controlling doctrinal issue governing the validity of RR GTTA-02. (b) Distinguish the standard...

Citations: National Internal Revenue Code (NIRC) and Revenue Regulations; BIR circulars interpreting RR (general authorities).

Congress enacts the Online Content Platforms Tax Act (OCPTA) authorizing the Secretary of Finance to issue regulation...

...cannot enforce a regulation that creates a new obligation beyond the National Internal Revenue Code (NIRC). (a) Identify the controlling doctrinal issue governing the validity of RR OCPTA-01. (b) Distinguish the standar...

Citations: National Internal Revenue Code (NIRC)

Vega Manufacturing Co., a domestic corporation, receives a Notice of Assessment for deficiency income tax for the tax...

...nt for deficiency income tax for the tax year 2023 from the Bureau of Internal Revenue (BIR). Within 30 days, Vega files a protest with the BIR. After the required processing period, the BIR issues a Decision on Protest...

Citations: National Internal Revenue Code of 1997, as amended (NIRC) – provisions on protest, decisions on protest, and review by the Court of Tax Appeals, Court of Tax Appeals Act (Republic Act No. 1125), as amended, BIR procedures on protest and decision on protest (as part of NIRC framework)

ZENITH Metals, Inc., a domestic corporation engaged in processing and export of metals, receives a Notice of Assessme...

...ccess to the courts, a common exam focus in medium-level assessments. National Internal Revenue Code of 1997, as amended (NIRC), Rules governi...

Citations: National Internal Revenue Code of 1997, as amended (NIRC), Rules governing Court of Tax Appeals and its jurisdiction in reviewing BIR protest decisions

Congress enacts the Telecommunication Services Revenue Act (TSRA), authorizing the Secretary of Finance to issue regu...

...holding as a tax collection mechanism under TSRA. The Commissioner of Internal Revenue (CIR) issues a circular aligning BIR dispositions with RR No. 2025-02. A Philippine-based platform, NetBridge, challenges RR No. 2025...

Citations: Republic Act No. 8424 (National Internal Revenue Code)

A VAT deficiency notice for 2024 is dated April 10, 2025. The taxpayer, Selene Imports, Inc., files a protest with th...

...ay, but the BIR records are not updated. On August 20, 2025, Selene’s internal mailroom locates the decision at the old address and forwards a copy to Selene’s Corporate Secretary. Selene files a Petition for Review with...

Citations: National Internal Revenue Code of 1997, as amended (NIRC), Court of Tax Appeals Act (CTA Act)

Facts: AeroNova Holdings, Inc., a domestic corporation, was assessed deficiency corporate income tax for 2018 after t...

...isallowed certain interest expense deductions under Section 34 of the National Internal Revenue Code in connection with related‑party loans. The Court of Tax Appeals ruled in favor of the BIR. AeroNova filed a Petition f...

Citations: Rule 65, Rules of Court, National Internal Revenue Code (NIRC) of the Philippines, as applicable

Digital Economy Tax Act (DETA) authorizes the Secretary of Finance to issue regulations necessary to implement and co...

...cannot enforce a regulation that creates a new obligation beyond the National Internal Revenue Code (NIRC). (a) Identify the controlling doctrinal issue governing the validity of RR No. DETA-01. (b) Distinguish the stan...

Citations: National Internal Revenue Code (Republic Act No. 8424)

Lumina Tech, Inc., a domestic corporation engaged in software development, receives a Notice of Assessment for defici...

..., frequently tested points in Administrative Remedies under the NIRC. National Internal Revenu...

Citations: National Internal Revenue Code of 1997, as amended

A NovaTech Industries, Inc., a corporate taxpayer subject to the National Internal Revenue Code, receives a Final Ass...

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)

In a criminal action for tax evasion under the National Internal Revenue Code, the Bureau of Internal Revenue (BIR) f...

In a criminal action for tax evasion under the National Internal Revenue Code, the Bureau of Internal Revenue (BIR) files a separate civil action for damages arising from the same offense in RTC Branch 50, Civil Case No...

In a criminal action for tax evasion under the National Internal Revenue Code, the offender, a corporation, is charge...

In a criminal action for tax evasion under the National Internal Revenue Code, the offender, a corporation, is charged in an information filed in the Regional Trial Court. The Bureau of Internal Revenue (the offended par...

Maple Tech, Inc., a VAT-registered taxpayer, is assessed PHP 5,750,000 by the Bureau of Internal Revenue (BIR) for a...

...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

Midasyr Co. owes deficiency VAT for 2021 in the amount of PHP 4,500,000. The Bureau of Internal Revenue (BIR) offers...

...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)

A Final Decision on Assessment (FDA) issued by the Bureau of Internal Revenue (BIR) on September 20, 2024, assesses A...

...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)