SAN BEDA UNIVERSITY

College of Law

COURSE SYLLABUS

For

TAXATION 1

COURSE CREDIT: 3 UNITS

TERM/ACADEMIC YEAR: FIRST SEMESTER SCHOOL YEAR 2021-2022

COURSE DELIVERY MODE: FULL ONLINE

COURSE DESCRIPTION:

A detailed evaluation of laws on taxation, national and local (excluding pertinent

portions of the NIRC which will form part of Taxation 2), including general
principles of taxation, limitations on taxation, sources of tax laws as well as
judicial and administrative remedies in taxation.

COURSE GOALS: Expected College of Law Graduate Attributes (ELGAs)

Know and understand the laws, cases and administrative issuances, memorize
important provisions and doctrines, critical and analytical thinking, effective in
written and oral communication, logical reasoning, and sound judgment, exercise
of proper professional and ethical responsibilities.

LEARNING OBJECTIVES/OUTCOMES (LOs):

1. Knowledge/Remembering: define, list, recognize

2. Comprehension/Understanding: describe, explain, identify, recognize
3. Application/Applying: choose, demonstrate, implement, perform
4. Analysis/Analyzing: analyze, categorize, compare, differentiate
5. Evaluation/Evaluating: assess, critique, evaluate, rank, rate
 6. Synthesis/Creating: construct, design, formulate, organize, synthesize

Upon completion of Taxation 1 course, the student is expected to be able to:

Expected College of LEARNING OUTCOMES (LOs)

Law Graduate
Attributes (ELGAs)

Critical and analytical LO1. Explain how law is created and enforced by executive,
thinking legislative, and regulatory bodies during class recitation and
discussion.

LO2. Analyze the practical and policy implications of current

Effective in written and and proposed statutes, regulations, judicial rulings, legal
oral communication arguments, and strategies in preparing a Legal Case.

LO3. Assess client concerns and translating them into

responsive legal arguments and strategies.
Logical reasoning
LO4. Utilize legal research tools to gather information that aids
in the analysis of legal issues in submitting the Research
Paper.
Sound judgment

Exercise of proper
professional and ethical
responsibilities

ASSESSMENT/GRADING SYSTEM:

The student will be graded according to the following:

Scope of Percentage
Work(Individual
Requirements (Based on the Learning Outcomes) ) (Weight is based
on
theimportance
of the LO)
 LO1Class recitations and Quizzes Individual

LO2 Individual

LO3 Individual

LO4 - - Research Paper/Case study –

optional on part of professor

Class Standing before Midterms Individual 16.67%

Midterm Examination Grade Individual 16.67%

Class Standing after Midterms Individual 33.33%

Final Examination Grade Individual 33.33%

TOTAL 100%

LEARNING PLAN:

Design or the structure of the course that includes content/topics to be covered;

learning resources to be used; weekly schedule of the topicst o be taken up; and
the learning methods to be utilized that are most likely to lead students towards
the goals and learning outcomes that were defined.
 TOPIC/CONTENT learning RESOURCES Week/ DATE LEARNING methods
(print and non-print (Schedule of
(arrangement or sequence of materials and online/ each Topic, (activities designed or
the major topics is based on open-access resources) Assign, Exam deployed by the
a logical order) for the entire teacher to bring
semester) about, or create the
conditions for
learning)

Course Introduction Syllabus

Course overview Lecture
Course assignments Student’s Handbook Aug. 16-28, Open Forum
Course requirements 2021 Discussion
Course expectations
Difficulty of hurdling
taxation subject in the
annual bar examinations

All subsequent Modules will be conducted under the following:

Recitations;
Lectures (optional on part of Professor); and
Quizzes.

Module 1 - General principles

a. Definition of Taxation - lifeblood theory

b. Definition of Taxes - it is a forced charge, imposition or

contribution, for revenue raising

c. Attributes of Taxation

it is a forced charge, imposition or contribution. It is not contractual,

either express or implied, but positive acts of the government
d. Characteristics of Taxes/Requisites of a Valid Tax

e. Kinds of taxes

1. Territorial Scope:
a. National (Donor’s - Estate - Excise/Sin Tax - Percentage
DocStamps - Income - VAT) vs local taxes (Real Estate Tax - Poll
Tax)
2. Who bears the burden:
a. indirect: the statutory taxpayer is allowed to pass on the burden to
pay but not the liability (ex VAT ; Percentage Tax; Final
Withholding Tax; Income Tax of Employees)
b. Direct: statutory TP shoulders the burden of paying (Income Tax
of Self Employed/Individuals; estate, donors)
3. As to subject matter:
a. Property - real or personal (what is taxed is the fact of ownership)
b. Privilege Tax - exercise of privilege to transfer property, going into
business, exercising profession
c. Personal or Poll tax - Community Tax / Cedula (what is taxed is
the fact of existing in a territory, in other words residence
4. Determination of Amount
a. Specific - based on a certain manner of measurement
b. Ad Valorem - based on the value of the article
5. According to Purpose
a. General - revenue raising in general (public purpose)
b. Special/Regulatory - raise revenue and to regulate behaviour
(such as excise tax on cigarettes , sugar sweetened beverages)
6. Graduation or Rate
a. Proportional/Proportionate - ex VAT; RPT
b. Progressive- ex income tax
c. Regressive

f. Taxation is Inherent Power of State - does not need to be

written into the constitution

g. Taxation distinguished from 2 other inherent powers

Tax PP ED
Purpose Lifeblood Theory Promotion of general Taking of
welfare - lawful means to private
taxation is lawful purpose property for
indispensable to the public use so
existence of long as with
government such that just
the government compensation
needs the
contribution of its
citizens in order to
function and operate

“the theory behind the

exercise of the power
to tax emanates from
necessity; without
taxes, government
cannot fulfill its
mandate of promoting
the general welfare
and well-being of the
people.”

Limitation Prohibition against So long as compliant with Section 9,

imprisonment due to the lawful purpose and Article III of the
non payment of poll lawful means (Test) 1987
tax Constitution

Constitutional Just
Limitations - list it compensation
here

Territoriality

h. Purposes/Objectives of Taxation

- Revenue raising or regulate

i. Aspects/Stages of Taxation

j. Characteristics/Principles of a Sound Tax System

 - Theoretical Justice/Equity: ability-to-pay principle
- Fiscal Adequacy: tax collected should be sufficient to defray the
necessary expenses for the government
- Administrative feasibility : cost to collect should not be more than
the tax collected
- Convenience: the tax should be levied at the time and the
manner which is most convenient for the taxpayer to pay it.

k. Taxes as distinguished from other impositions/exactions/levies

Tax License/ Fees Penalties and

Surcharges

Revenue Defray the cost Punishment for

Generating of providing the violation of law
service and/or
to regulate
activities

l. Taxes vs. Set Off/Legal Compensation

- No application in the Philippines because (govt and TP are not creditor

and debtor of each other)

m. Equitable Recoupment

- When the statute of limitations / prescription period has run out either to
collect (on the part of the Govt) or to refund (on the part of the TP) and
you want to offset against a tax due to be paid or due to be refunded -
(Not applicable in the Philippines)

n. Lifeblood Doctrine - “the theory behind the exercise of the

power to tax emanates from necessity; without taxes, the government
cannot fulfill its mandate of promoting the general welfare and well-
being of the people.”

o. Necessity Theory - the existence of government is a necessity;

that it cannot continue without means to pay its expenses; and that for
these means, it has a right to compel all its citizens and property
within its limits to contribute.
p. Benefits-Protection Theory (Symbiotic relationship) - you pay
for the benefit and protection you receive from the government

q. Power to Tax involves the Power to Destroy - As a general rule,

the power to tax is an incident of sovereignty and is unlimited in its
range, acknowledging in its very nature no limits, so that security
against its abuse is to be found only in the responsibility of the
legislature which imposes the tax on the constituency who is to pay it.
So potent indeed is the power that it was once opined that the power
to tax involves the power to destroy. The power of taxation is
sometimes called also the power to destroy. Therefore it should be
exercised with caution to minimize injury to the proprietary rights of a
taxpayer. It must be exercised fairly, equally and uniformly, lest the
tax collector "kill the hen that lays the golden egg." (Tridharma
Marketing Corporation vs. CTA, G.R. No. 215950, June 20, 2016)

r. Kinds of Double Taxation

"direct duplicate taxation," the two taxes must be imposed on

the same subject matter, for the same purpose, by
the same taxing authority, within the same jurisdiction,
during the same taxing period; and the taxes must be
of the same kind or character.

Double Taxation -

s. Kinds of Tax Exemptions

t. Principles/Interpretations/Construction on Tax Laws and Tax

Exemptions

u. Prospectivity of Tax Laws

v. Prescriptability/Imprescriptibility of Taxes

w. Forms of Escape from Taxation

x. Difference between Tax Evasion vs. Tax Avoidance

y. Tax refund

z. Tax credit
 aa. Tax amnesty

bb. Compromise vs. abatement

SEC. 204. Authority of the Commissioner to Compromise, Abate and Refund or Credit
Taxes. –

The Commissioner may –

(A) Compromise the payment of any internal revenue tax, when:

(1) A reasonable doubt as to the validity of the claim against the taxpayer exists; or

(2) The financial position of the taxpayer demonstrates a clear inability to pay the assessed tax.

The compromise settlement of any tax liability shall be subject to the following minimum
amounts:

For cases of financial incapacity, a minimum compromise rate equivalent to ten percent (10%)
of the basic assessed tax; and

For other cases, a minimum compromise rate equivalent to forty percent (40%) of the basic
assessed tax.

Where the basic tax involved exceeds One million pesos (P1,000.000) or where the settlement
offered is less than the prescribed minimum rates, the compromise shall be subject to the
approval of the Evaluation Board which shall be composed of the Commissioner and the four (4)
Deputy Commissioners.

(B) Abate or cancel a tax liability, when:

(1) The tax or any portion thereof appears to be unjustly or excessively assessed; or

(2) The administration and collection costs involved do not justify the collection of the amount
due.
All criminal violations may be compromised except: (a) those already filed in court, or (b) those
involving fraud.

cc. Judicial Review of Taxation

dd. Taxpayer’s Suit -

https://www.chanrobles.com/cralaw/1994maydecisions.php?id=523

ee. Read selected cases

(i) CIR vs. ALGUE, INC. [G.R. No. L-28896. February 17,
1988.]

(ii) REPUBLIC vs. MAMBULAO LUMBER [G.R. No. L-17725.

February 28, 1962.]

And the weight of authority is to the effect that internal revenue taxes, such as the forest
charges in question, can be the subject of set-off or compensation.

A claim for taxes is not such a debt, demand, contract or judgment as is allowed to be set-off
under the statutes of set-off, which are construed uniformly, in the light of public policy, to
exclude the remedy in an action or any indebtedness of the state or municipality to one who is
liable to the state or municipality for taxes. Neither are they a proper subject of recoupment
since they do not arise out of the contract or transaction sued on. ... (80 C.J.S. 73-74. ) .

The general rule, based on grounds of public policy is well-settled that no set-off is admissible
against demands for taxes levied for general or local governmental purposes. The reason on
which the general rule is based, is that taxes are not in the nature of contracts between the
party and party but grow out of a duty to, and are the positive acts of the government, to the
making and enforcing of which, the personal consent of individual taxpayers is not required. ... If
the taxpayer can properly refuse to pay his tax when called upon by the Collector, because he
has a claim against the governmental body which is not included in the tax levy, it is plain that
some legitimate and necessary expenditure must be curtailed. If the taxpayer's claim is
disputed, the collection of the tax must await and abide the result of a lawsuit, and meanwhile
the financial affairs of the government will be thrown into great confusion. (47 Am. Jur. 766-
767.)
 (iii) ENGRACIO FRANCIA vs. IAC [G.R. No. L-67649. June
28, 1988.]

(iv) MELECIO R. DOMINGO vs. HON. LORENZO C.

GARLITOS [G.R. No. L-18994. June 29, 1963.]

(v) Executive Secretary vs. Southwing Heavy Industries

(G.R. No. 164171, February 20, 2006)

(vi) John Hay People’s Alternative Coalition vs. Lim (G.R. No.
119775, October 24, 2003)

(vii) Delpher Trades Corp and Pacheco vs. IAC (G.R. No. L-
69259, January 26, 1988)

(viii) CIR vs. Lincoln Philippine Life Insurance (G.R. No.

119176, March 19, 2002)

Finally, it should be emphasized that while tax avoidance schemes and

arrangements are not prohibited, tax laws cannot be circumvented in
order to evade the payment of just taxes. In the case at bar, to claim that
the increase in the amount insured (by virtue of the automatic increase
clause incorporated into the policy at the time of the computation of the
issuance) should not be included documentary stamp taxes due on the
policy would be a clear evasion of the law requiring that the tax be
computed on the basis of the amount insured by the policy.

(ix) CIR vs. Estate of Benigno Toda (G.R. No. 147188,

September 14, 2004)

Is this a case of tax evasion or tax avoidance?

Tax avoidance and tax evasion are the two most common ways used by taxpayers in escaping
from taxation. Tax avoidance is the tax saving device within the means sanctioned by law. This
method should be used by the taxpayer in good faith and at arms length. Tax evasion, on the
other hand, is a scheme used outside of those lawful means and when availed of, it usually
subjects the taxpayer to further or additional civil or criminal liabilities.23

Tax evasion connotes the integration of three factors: (1) the end to be achieved, i.e., the
payment of less than that known by the taxpayer to be legally due, or the non-payment of tax
when it is shown that a tax is due; (2) an accompanying state of mind which is described as
being "evil," in "bad faith," "willfull," or "deliberate and not accidental"; and (3) a course of action
or failure of action which is unlawful.24
All these factors are present in the instant case. It is significant to note that as early as 4 May
1989, prior to the purported sale of the Cibeles property by CIC to Altonaga on 30 August 1989,
CIC received ₱40 million from RMI,25 and not from Altonaga. That ₱40 million was debited by
RMI and reflected in its trial balance26 as "other inv. – Cibeles Bldg." Also, as of 31 July 1989,
another ₱40 million was debited and reflected in RMI’s trial balance as "other inv. – Cibeles
Bldg." This would show that the real buyer of the properties was RMI, and not the intermediary
Altonaga.lavvphi1.net

The investigation conducted by the BIR disclosed that Altonaga was a close business associate
and one of the many trusted corporate executives of Toda. This information was revealed by Mr.
Boy Prieto, the assistant accountant of CIC and an old timer in the company. 27 But Mr. Prieto did
not testify on this matter, hence, that information remains to be hearsay and is thus inadmissible
in evidence. It was not verified either, since the letter-request for investigation of Altonaga was
unserved,28 Altonaga having left for the United States of America in January 1990.
Nevertheless, that Altonaga was a mere conduit finds support in the admission of respondent
Estate that the sale to him was part of the tax planning scheme of CIC. That admission is borne
by the records. In its Memorandum, respondent Estate declared:

Petitioner, however, claims there was a "change of structure" of the proceeds of sale. Admitted
one hundred percent. But isn’t this precisely the definition of tax planning? Change the structure
of the funds and pay a lower tax. Precisely, Sec. 40 (2) of the Tax Code exists, allowing tax free
transfers of property for stock, changing the structure of the property and the tax to be paid. As
long as it is done legally, changing the structure of a transaction to achieve a lower tax is not
against the law. It is absolutely allowed.

Tax planning is by definition to reduce, if not eliminate altogether, a tax. Surely petitioner [sic]
cannot be faulted for wanting to reduce the tax from 35% to 5%.29 [Underscoring supplied].

The scheme resorted to by CIC in making it appear that there were two sales of the subject
properties, i.e., from CIC to Altonaga, and then from Altonaga to RMI cannot be considered a
legitimate tax planning. Such scheme is tainted with fraud.

Fraud in its general sense, "is deemed to comprise anything calculated to deceive, including all
acts, omissions, and concealment involving a breach of legal or equitable duty, trust or
confidence justly reposed, resulting in the damage to another, or by which an undue and
unconscionable advantage is taken of another."30

Here, it is obvious that the objective of the sale to Altonaga was to reduce the amount of tax to
be paid especially that the transfer from him to RMI would then subject the income to only 5%
individual capital gains tax, and not the 35% corporate income tax. Altonaga’s sole purpose of
acquiring and transferring title of the subject properties on the same day was to create a tax
shelter. Altonaga never controlled the property and did not enjoy the normal benefits and
burdens of ownership. The sale to him was merely a tax ploy, a sham, and without business
purpose and economic substance. Doubtless, the execution of the two sales was calculated to
mislead the BIR with the end in view of reducing the consequent income tax liability.lavvphi1.net
In a nutshell, the intermediary transaction, i.e., the sale of Altonaga, which was prompted more
on the mitigation of tax liabilities than for legitimate business purposes constitutes one of tax
evasion.31

Generally, a sale or exchange of assets will have an income tax incidence only when it is
consummated.32 The incidence of taxation depends upon the substance of a transaction. The
tax consequences arising from gains from a sale of property are not finally to be determined
solely by the means employed to transfer legal title. Rather, the transaction must be viewed as a
whole, and each step from the commencement of negotiations to the consummation of the sale
is relevant. A sale by one person cannot be transformed for tax purposes into a sale by another
by using the latter as a conduit through which to pass title. To permit the true nature of the
transaction to be disguised by mere formalisms, which exist solely to alter tax liabilities, would
seriously impair the effective administration of the tax policies of Congress.33

To allow a taxpayer to deny tax liability on the ground that the sale was made through another
and distinct entity when it is proved that the latter was merely a conduit is to sanction a
circumvention of our tax laws. Hence, the sale to Altonaga should be disregarded for income tax
purposes.34 The two sale transactions should be treated as a single direct sale by CIC to RMI.

(x) City of Iloilo vs. Smart Communications (G.R. No.

167260, February 27, 2009)

The basic principle in the construction of laws granting tax exemptions has been very stable. As
early as 1916, in the case of Government of the Philippine Islands v. Monte de Piedad, 5 this
Court has declared that he who claims an exemption from his share of the common burden of
taxation must justify his claim by showing that the Legislature intended to exempt him by words
too plain to be beyond doubt or mistake. This doctrine was repeated in the 1926 case of Asiatic
Petroleum v. Llanes,6 as well as in the case of Borja v. Commissioner of Internal Revenue
(CIR)7 decided in 1961. Citing American jurisprudence, the Court stated in E. Rodriguez, Inc. v.
CIR:8

The right of taxation is inherent in the State. It is a prerogative essential to the perpetuity of the
government; and he who claims an exemption from the common burden, must justify his claim
by the clearest grant of organic or statute law xxx When exemption is claimed, it must be shown
indubitably to exist. At the outset, every presumption is against it. A well-founded doubt is fatal
to the claim; it is only when the terms of the concession are too explicit to admit fairly of any
other construction that the proposition can be supported.

(xi) National Power Corporation vs. CBAA (G.R. No. 171470,

January 30, 2009)
The power to tax is an incident of sovereignty and is unlimited in its magnitude, acknowledging
in its very nature no perimeter so that security against its abuse is to be found only in the
responsibility of the legislature which imposes the tax on the constituency who are to pay for it.
The right of local government units to collect taxes due must always be upheld to avoid severe
tax erosion. This consideration is consistent with the State policy to guarantee the autonomy of
local governments and the objective of the Local Government Code that they enjoy genuine and
meaningful local autonomy to empower them to achieve their fullest development as self-reliant
communities and make them effective partners in the attainment of national goals.

In conclusion, we reiterate that the power to tax is the most potent instrument to raise the
needed revenues to finance and support myriad activities of the local government units for the
delivery of basic services essential to the promotion of the general welfare and the
enhancement of peace, progress, and prosperity of the people. [Emphasis supplied.]

This ruling reminds us of the other side of the coin in terms of concerns and protection of
interests. La Union, as a local government unit, has no less than its own constitutional interests
to protect in pursuing this case. These are interests that this Court must also be sensitive to and
has taken into account in this Decision.

We close with the observation that our role in addressing the concerns and the interests at
stake is not all-encompassing. The Judiciary can only resolve the current dispute through our
reading and interpretation of the law. The other branches of government which act on policy and
which execute these policies, including NAPOCOR itself and the respondent local government
unit, are more in the position to act in tackling feared practical consequences. This ruling on the
law can be their springboard for action.

(xii) Winebrenner & Inigo Insurance Brokers, Inc. vs. CIR

(G.R. 206526, January 28, 2015)

The Court recognizes, as it always has, that the burden of proof to establish entitlement to
refund is on the claimant taxpayer. 16 Being in the nature of a claim for exemption, 17 refund is
construed in strictissimi juris against the entity claiming the refund and in favor of the taxing
power.18 This is the reason why a claimant must positively show compliance with the statutory
requirements provided for under the NIRC in order to successfully pursue one’s claim. As
implemented by the applicable rules and regulations and as interpreted in a vast array of
decisions, a taxpayer who seeks a refund of excess and unutilized CWT must:

1) File the claim with the CIR within the two year period from the date of payment of the tax;

2) Show on the return that the income received was declared as part of the gross income; and
3) Establish the fact of withholding by a copy of a statement duly issued by the payor to the
payee showing the amount paid and the amount of tax withheld.19

(xiii) Fluor Daniel Phil. Inc. vs. CIR (G.R. No. 212895,
November 27, 2019)

(xiv) China Banking Corp. vs. CIR (G.R. 172509, February 4,

2015)

(xv) CBK Power Co. Ltd. Vs. CIR (G.R. 193383-84, January
14, 2015)p

(xvi) Philippine National Bank vs. CIR (G.R. 206019, March 18,
2015)

(xvii) Covanta Energy Philippine Holdings Inc. vs. CIR, G.R.

203160, January 24, 2018

As the Court previously held in CS Garment, Inc. v. CIR,40 taxpayers are

eligible to the immunities of the tax amnesty program as soon
as they fulfill the suspensive conditions imposed under R.A.
No. 9480:

A careful scrutiny of the 2007 Tax Amnesty Law would tell us that the law contains
two types of conditions one suspensive, the other resolutory. Borrowing from the
concepts under our Civil Code, a condition may be classified as suspensive when
the fulfillment of the condition results in the acquisition of rights. On the other hand,
a condition may be considered resolutory when the fulfillment of the condition
results in the extinguishment of rights. In the context of tax amnesty, the rights
referred to are those arising out of the privileges and immunities granted under the
applicable tax amnesty law.

xxxx
This clarification, however, does not mean that the amnesty taxpayers would
go scot-free in case they substantially understate the amounts of their net
worth in their SALN. The 2007 Tax Amnesty Law imposes a resolutory condition
insofar as the enjoyment of immunities and privileges under the law is concerned.
Pursuant to Section 4 of the law, third parties may initiate proceedings contesting
the declared amount of net worth of the amnesty taxpayer within one year following
the date of the filing of the tax amnesty return and the SALN. Section 6 then states
that "All these immunities and privileges shall not apply x x x where the amount of
networth as of December 31, 2005 is proven to be understated to the extent of thirty
percent (30%) or more, in accordance with the provisions of Section 3 hereof."
Accordingly, Section 10 provides that amnesty taxpayers who willfully understate
their net worth shall be (a) liable for perjury under the Revised Penal Code; and (b)
subject to immediate tax fraud investigation in order to collect all taxes due and to
criminally prosecute those found to have willfully evaded lawful taxes due. 41
(Emphasis Ours)

Considering that CEPHI completed the requirements and paid the

corresponding amnesty tax, it is considered to have totally
complied with the tax amnesty program. As a matter of course,
CEPHI is entitled to the immediate enjoyment of the
immunities and privileges of the tax amnesty program. 42
Nonetheless, the Court emphasizes that the immunities and
privileges granted to taxpayers under R.A. No. 9480 is not
absolute. It is subject to a resolutory condition insofar as
the taxpayers' enjoyment of the immunities and privileges
of the law is concerned. These immunities cease upon proof
that they underdeclared their net worth by 30%.

Unfortunately for the CIR, however, there is no such proof in CEPHI's

case. The Court, thus, finds it necessary to deny the present
petition. While tax amnesty is in the nature of a tax exemption,
which is strictly construed against the taxpayer,43 the Court
cannot disregard the plain text of R.A. No. 9480.

(xviii) Philippine Airlines vs. CIR, G.R. 206079-80, January 17,

2018
Lastly, while tax exemptions are strictly construed against the taxpayer, the government should
not misuse technicalities to keep money it is not entitled to.

Substantial justice, equity and fair play are on the side of petitioner. Technicalities
and legalisms, however exalted, should not be misused by the government to keep
money not belonging to it, thereby enriching itself at the expense of its law-abiding
citizens. Under the principle of solutio indebiti provided in Art. 2154, Civil Code, the
BIR received something "when there [was] no right to demand it," and thus, it has
the obligation to return it. Heavily militating against respondent Commissioner is the
ancient principle that no one, not even the state, shall enrich oneself at the expense
of another. Indeed, simple justice requires the speedy refund of the wrongly held
taxes.163 (Citations omitted)

Considering that PAL presented sufficient proof that: (i) it is exempted from paying withholding
taxes; (ii) amounts were withheld and deducted from its accounts; (iii) and the Commissioner did
not contest the withholding of these amounts and only raises that they were not proven to be
remitted, this Court finds that PAL sufficiently proved that it is entitled to its claim for refund.

(xix) University Physicians Services Inc. vs. CIR, G.R. 205955,

March 7, 2018

(xx) Bank of the Philippine Islands vs. CIR, G.R. 224327, June
11, 2018

To proceed heedlessly with tax collection without first establishing a valid

assessment is evidently violative of the cardinal principle in
administrative investigations: that taxpayers should be able to
present their case and adduce supporting evidence. 16
Although taxes are the lifeblood of the government, their
assessment and collection "should be made in accordance
with law as any arbitrariness will negate the very reason for
government itself."17

(xxi) Asian Transmission Corp. vs. CIR, G.R. 230861, Sept. 19,
2018

(xxii) Land Bank of the Phil. Vs. Cacayuran, G.R. 191867, april
2013

It is hornbook principle that a taxpayer is allowed to sue where there is a claim that public funds
are illegally disbursed, or that public money is being deflected to any improper purpose, or that
there is wastage of public funds through the enforcement of an invalid or unconstitutional law.
A person suing as a taxpayer, however, must show that the act complained of directly involves
the illegal disbursement of public funds derived from taxation. In other words, for a taxpayer’s
suit to prosper, two requisites must be met namely, (1) public funds derived from taxation are
disbursed by a political subdivision or instrumentality and in doing so, a law is violated or some
irregularity is committed; and (2) the petitioner is directly affected by the alleged act.31

Module 2 - Limitations

a. Constitutional Limitations – Memorize all tax related provisions

(direct and indirect). Read entire 1987 Constitution again

b. 5 Inherent Limitations

1. Public purpose;

2. Non-delegability of power;

3. Territoriality or situs of taxation;

4. Exemption of government from taxation; and

5. International Comity

c. Tax Treaty – Read and compare RP-USA Tax Treaty and RP-
China Tax Treaty

d. Review landmark cases under PoliLaw relating to constitutional

and inherent limitations

e. Read selected cases

(i) Bagatsing vs. Ramirez [G.R. No. L-41631. December

17, 1976.]

(ii) Abakada Guro Party List vs. Executive Secretary [G.R.

No. 168056. September 1, 2005.]
 (iii) Eastern Theatrical vs. Alfonso [G.R. No. L-1104. May 31,
1949.]

(iv) British American Tobacco vs. Camacho [G.R. No.

163583. August 20, 2008 and April 15, 2009.]

(v) La Sallian Educational Innovators Foundation vs. CIR,

G.R. 202792, February 27, 2019

Module 3 - Sources of Tax Laws (NIRC)

a. Sections 1 to 21 (Organization and Function of the BIR plus

sources of revenues)

CIR - collect taxes and interpret tax laws cf

DCIRs -

Large Taxpayer Service -

REgional Directors - Revenue Regions sec 6

Revenue District Officer sec 7

b. Section 23 (General Principles of Income Taxation

- Source Principle
- Citizenship
- Residency

DTA

c. Section 42 (Income from sources within the Philippines)

d. Sections 202 to 231 (Remedies in General)

e. Sections 244 – 246 (Rules and Regulations)

f. Sections 247 to 249 (Penalties/Additions to Tax)

g. Memorize Sections 203, 204, 222, 228 and 246

h. Study RevRegs No. 12-1999, RevRegs No. 18-2013, RevRegs
No. 7-2018, RMO No. 26-2016, and RMC No. 11-2014 (Section 228);

i. Study RevRegs No. 30-2002, RevRegs No. 08-2004, RevRegs

No. 9-2013, and RMC No. 34-2014;

j. Study RMO No. 20-1990, RDAO No. 05-2001, RMC No. 06-
2005, RMC No. 29-2012 and RMO No. 14-2016 (waivers);

k. Read selected cases:

(i) Commissioner of Internal Revenue vs.

Isabela Cultural (361 SCRA 71);

(ii) Commissioner of Internal Revenue vs.

Union Shipping Corp (185 SCRA 547);

(iii) Advertising Associates vs. CA (133 SCRA

765);

(iv) Commissioner of Internal Revenue vs. Metro

Star Superama Inc. (GR No. 185371, Dec 8, 2010);

(v) Lascona Land vs. Commissioner of

Internal Revenue (GR No. 171251, March 5,
2012);

(vi) Rohm vs. CIR (GR No. 168950, Jan 14,

2015);

(vii) RCBC vs. CIR (GR No. 170257, Sept 7, 2011);

(viii) CIR vs. Hambrecht (GR No. 169225, Nov 17,

2010);

(ix) CIR vs. Next Mobile (GR No. 212825, Dec.

7, 2015);

(x) Lanao Del Norte Electric Cooperative vs.

CIR, CTA Case No. 8769 dated October 11,
2019;

(xi) CIR vs. Azucena Reyes, GR No. 159694

dated January 27, 2006;

(xii) Association of Non-Profit Clubs Inc. vs. CIR,

G.R. 228539, June 26, 2019;

(xiii) Banco de Oro vs. CIR ( G.R. 198756, January

13, 2015);
 Module 4 - Custom Modernization and Tariff Act (CMTA)
a.
b.
c.
d.
MIDTERMS CUT-OFF (actual midterms exam date - TBD)
Module 5 - Local Taxation
a.
Provinces
Except as otherwise provided in the
LGC, the province may levy only the
taxes, fees, and charges as provided in
this Article. (LGC, Sec. 134)
For provinces, they are limited to
what is prescribed in the LGC, as the
word is “only.”
Read Sections 103, 104, 106, 113, 114, 120, 401, 402, 404,
423, 700, 701, 702, 703, 704, 705, 706, 709, 714, 800, 900, 913,
1000, 1002, 1003, 1100, 1106, 1126, 1127, 1128, 1136
Memorize all Special Duties & Trade Remedy Measures
Read selected cases
Read selected BOC issuances
Read Sections 128 to 196 – RA No. 7160 (LGC)
Specific Taxing Power of Local Government Units
Municipalities Cities Barangays
Except as otherwise provided in the Except as otherwise provided in The barangays may levy the following taxes
LGC, the municipalities may levy the LGC, the and charges, which shall EXCLUSIVELY
taxes, fees and charges not otherwise city may levy the taxes, fees, accrue to them.
levied by provinces. (LGC, Sec. 142)
and charges which the
province or municipality may
impose. (LGC, Sec. 151)
• Tax on Transfer of Real • Tax on Business • Any of the taxes, fees, The following shall accrue
Property • Rates of Tax within the charges, and other EXCLUSIVELY to barangay:
Exempt - disposition Metropolitan Manila impositions that the • Barangay Taxes
pursuant to CARL of 1988 Area province (Sec. 135-141) • Service Fees or Charges
• Tax on Business of • Retirement of and municipality (Sec. • Barangay Clearance
Printing and Publication Business 143-149) may impose. • Other Fees and Charges
Exempt - receipts from • Payment of Business • A percentage tax on o Commercial
reading materials Taxes any business not breeding of
prescribed by DECS • Fees and Charges otherwise specified fighting cocks,
• Franchise Tax • Fees for Sealing and under Sec. 143 (Tax on cockfights and
• Tax on Sand, Gravel Licensing of Weights various types of cockpits
and Other Quarry and Measures business No. 1-7), at o Places of
Resources • Fishery Rentals, Fees rates not exceeding 3% recreations
• Professional Tax and Charges of the gross sales or which charge
Exempt - professionals receipts of the admission fees
exclusively employed in the preceding calendar o Billboards,
gov’t. year. (IRR of LGC, Art. 237) signboards,
• Amusement Tax neon signs and
Exempt -operas, concerts, outdoor
dramas, recitals, art advertisements
exhibits, flower shows,
literary and oratorical
presentations, except pop,
rock, or similar concerts
• Annual Fixed Tax For
Every Delivery Truck or
Van of Manufacturers
or Producers,
Wholesalers of,
Dealers, or Retailers in,
Certain Products
Exempt - manufacturers,
producers, wholesalers,
dealers or retailers of
distilled spirits, fermented
liquors, soft drinks, cigars
and cigarettes, and other
products as may be
determined by the
Sangguniang Panlalawigan
are exempt from tax on
peddlers

Common Revenue Raising Powers

Provinces Municipalities Cities Barangays

a) Service Fees and Charges for services rendered. (LGC, Sec. 153)
b) Public Utility Charges for the operation of public utilities owned, operated and maintained by LGUs within their
jurisdiction. (LGC, Sec. 154)
c) Toll Fees or Charges for the use of any public road, pier, or wharf, waterway, bridge, ferry or telecommunication system
funded and constructed by the LGU concerned. (LGC, Sec. 155)

Community Tax

Provinces Municipalities Cities Barangays

CANNOT levy a community CAN levy a community tax CAN levy a community tax CANNOT levy a community tax
tax
 Professional Tax

Provinces Municipalities Cities Barangays

CAN levy a professional tax CANNOT levy a professional CAN levy a professional tax CANNOT levy a professional tax
tax
 b. Memorize Sections 130 (Fundamental Principles), 133
(Common Limitations), 150 (Situs), and 195 (Protest).

c. Read pertinent portions of IRR of LGC related to item (a)

above

d. Read selected cases

(i) Demaala vs. Comm. On Audit , ( G.R. 199752,

February 17, 2015);

(ii) Prieto vs. City of Manila, G.R. 221366, July 18, 2019;

(iii) Randy Allied Ventures Inc. vs. City of Davao, G.R.

241697, July 29, 2019;p

(iv) Cosmos Bottling Corp. vs. City of Manila, G.R. 196681,

June 27, 2018;

(v) Noemi Cruz vs. City of Makati, G.R. 210894, September

12, 2018.

e. Read selected local finance circulars/DILG circulars

Module 6 - Real Property Taxation

a. Read Sections 197 to 283 – RA No. 7160 (LGC)

b. Memorize Section 198 (Fundamental Principles), 215 (Classes

of Real Property), 216 (Special Classes), 234 (Exemptions), 235
(SEF), 236 to 238 (Idle lands) and 270 (Period to collect)

c. Read pertinent portions of IRR of LGC related to item (a)

above

d. Read selected cases:

 (i) Mactan-Cebu Int’l Airport Authority vs. Lapu-Lapu City
(G.R. 181756, June 15, 2015);

(ii) National Power Corp. vs. Province of Pangasinan, G.R.

210191, March 4, 2019;

(iii) University of the Philippines vs. City Treasurer of Quezon

City, G.R. 214044, June 19, 2019;

e. Read selected local finance circulars/DILG circulars

Module 7 - CTA/Judicial Remedies

1. CTA Jurisdiction under CTA Laws (RA No. 1125, 9282 and 9503) –
collection of taxes, civil cases and criminal cases, appeal to CTA En Banc,
Petition for Review to SC

Through the enactment of Republic Act No. 9282, the jurisdiction of the CTA has been expanded to include not
only civil tax cases but also cases that are criminal in nature, as well as local tax cases, property taxes and final
collection of taxes.

Pursuant to the provisions of Republic Act No. 1125 and other laws prior to R.A. 9282, the Court of Tax Appeals
retains exclusive appellate jurisdiction to review by appeal, the following:

1. Decisions of the Commissioner of Internal Revenue in cases involving disputed assessments,

refunds of internal revenue taxes, fees or other charges, penalties imposed in relation thereto,
or other matters arising under the National Internal Revenue Code or other law or part of law
administered by the Bureau of Internal Revenue;
2. Decisions of the Commissioner of Customs in cases involving liability for customs duties, fees or
other money charges; seizure, detention or release of property affected; fines, forfeitures or
other penalties imposed in relation thereto; or other matters arising under the Customs Law or
other law or part of law administered by the Bureau of Customs [Rep. Act. No. 1125, (1954),
Sec. 7];
3. In automatic review cases where such decisions of the Commission of Customs favorable to the
taxpayer is elevated to the Secretary of Finance (Sec. 2315, TCC); and
4. Decisions of the Secretary of Trade and Industry, in the case of non-agricultural product,
commodity or article, or the Secretary of Agriculture, in the case of agricultural product,
commodity or article, in connection with the imposition of the Anti-Dumping Duty,
Countervailing and Safeguard Duty [Republic Act Nos. 8751 and 8752, (1999) Sec. 301 (a) and
(p), and Republic Act 8800].

Under Republic Act Number 9282, the CTA's original appellate jurisdiction was expanded to include the following:

1. Criminal cases involving violations of the National Internal Revenue Code and the Tariff and
Customs Code;
2. Decisions of the Regional Trial Courts (RTC) in local tax cases;
 3. Decisions of the Central Board of Assessment Appeals (CBAA) in cases involving the assessment
and taxation of real property; and
4. Collection of internal revenue taxes and customs duties the assessment of which have already
become final.

2. CTA Rules of Court

3. Suspension of collection of taxes

4. Review again remedies under NIRC, CMTA and LGC and correlate with
CTA Laws/Rules of Court

5. Read selected cases

a. V.Y. Domingo Jewellers, Inc. vs. CIR, G.R. 221780, March 25,
2019;GR No. 221780 - COMMISSIONER OF INTERNAL
REVENUE, PETITIONER, v. VY DOMINGO JEWELLERS, INC.,
RESPONDENT. : March 2019 - Philipppine Supreme Court
Decisions

b. Roca Security & Investigation Agency Inc. vs. CIR, G.R.

241338, April 10, 2019;

c. Misnet Inc. vs. CIR, G.R. 210604, June 3, 2019.

FINALS EXAMINATIONS (actual finals exam date - TBD)

TEXTBOOK/REFERENCE BOOK:

Read as many taxation books as possible

POLICIES:

Policies and values that the professor might want to communicate through the
syllabus concerning attendance, participation, academic integrity (e.g.plagiarism,
cheating, fabrication), missing assignments, missed exams, recording classroom
activities, online behavior during synchronous sessions, etc.

1. Attendance will be checked by the beadle every online meeting.

2. Students who missed an announced quiz will get a grade of 65.

 3. Students are prohibited from recording the online class as this is a violation of the
Copyright of the Professor.

Approved by:

Atty. Marciano G. Delson

Dean, College of Law

Title II. Tax on Income

Chapter I - Definitions
Section 22 Definitions

Chapter II - General Principles

Section 23 General Principles of Income Taxation in the Philippines
1. Citizenship
2. Residency
3. Source

● DTA

Chapter III - Tax on Individuals

Section 24 Tax Rates
(A) Rates of Income Tax on Individual Citizen and Individual Resident Alien of
the Philippines
Graduated
(B) Rate of Tax on Certain Passive Income
10-20% (interest, royalties, prizes, and winnings)
(C) Capital Gains from Sale of Shares of Stock not Traded in the Stock
Exchange
15% of net gain
(D) Capital Gains from Sale of Real Property
(held as a capital asset) - 6% GSP or FMV whichever is higher

Capital vs Ordinary Asset

Capital is asset which is not ordinary

Ordinary Asset - stock in trade or inventory or used in trade or biz

 Section 25 Tax on Nonresident Alien Individual
(A) Nonresident Alien Engaged in trade or Business Within the
Philippines
Graduated rate (more than 180 days in the Philippines = NRAETB
(B) Nonresident Alien Individual Not Engaged in Trade or
Business Within the Philippines
25%
(C) Alien Individual Employed by Regional or Area Headquarters and Regional
Operating Headquarters of Multinational Companies.
15% on gross
(D) Alien Individual Employed by Offshore Banking Units
15% on gross
(E) Alien Individual Employed by Petroleum Service Contractor and
Subcontractor
15% on gross

**** Filipinos employes by RHQ ROHQ OBUS and PSCS if employed as

managerial or technical employees AND actually doing work as such 15% on
gross

Section 26 Tax Liability of Members of General Professional Partnerships

GPPS = pass through entities

MEI

Chapter IV - Tax on Corporations

Section 27 Rates of Income Tax on Domestic Corporations
(A) In General 30% on NTI (RCIT)
(B) Proprietary Educational Institutions and Hospitals (10%)
(C) Government-owned or –Controlled Corporations, Agencies or
Instrumentalities RCIT except SSS GSIS PHILHEALTH and LWDi
(D) Rates of Tax on Certain Passive Incomes- similar to individuals except intra
corp dividends are not taxed
(E) Minimum Corporate Income Tax on Domestic Corporations.
Applicable on 4th year of operations
2% of GI
Applied if RCIT is LOWER than MCIT
May not apply if SoF Allows due to
Prolonged labor dispute,
force majeure,
serious business losses
Section 28 Rates of Income Tax on Foreign Corporations
(A) Tax on Resident Foreign Corporations
RCIT NTI on income earned in the Philippines
15% on GI
MCIT

- International Carrier 2 ½ Gross Philippine Billings (passengers

and cargo that original in the Philippines)
- International Shipping
- OBU 10% FIT on FDCU
 - BPRT 15% total profits / RCIT If income or profit is not remitted
-
(B) Tax on Nonresident Foreign Corporation
GI 30%

Section 29 Imposition of Improperly Accumulated Earnings Tax

(A) In General 10% of the improperly accumulated earnings
EXEMPT
- publicly-held corporations,
- banks and other nonbank financial
intermediaries,
- insurance companies,
(B) Tax on Corporations Subject to Improperly Accumulated Earnings Tax
(C) Evidence of Purpose to Avoid Income Tax
(D) Improperly Accumulated Taxable Income

Improperly accumulated taxable income” means current year taxable income

adjusted by:

1. Income exempt from tax;

2. Income excluded from gross income;

3. Income subject to final tax; and

4. The amount of net operating loss carry-over deducted;

And reduced by the sum of:

5. Dividends actually or constructively paid; and

6. Income tax paid for the taxable year.

(E) Reasonable Needs of the Business

As a general rule, Section 42 of the Revised Corporation Code of the Philippines
prohibits stock corporations from retaining or accumulating surplus profits in
excess of its paid-in capital (capital stock and additional paid in capital
combined). It shall be noted that if the accumulation of profit is justifiable and
within the reasonable business needs of the Company, which shall be properly
supported and documented, it shall not be referred to as an improper
accumulation.

Section 30 Exemptions from Tax on Corporations

(A) Labor, agricultural or horticultural organization not organized principally for

profit;

(B) Mutual savings bank not having a capital stock represented by shares, and
cooperative bank without capital stock organized and operated for mutual
purposes and without profit;
(C) A beneficiary society, order or association, operating for the exclusive benefit
of the members such as a fraternal organization operating under the lodge
system, or mutual aid association or a nonstock corporation organized by
employees providing for the payment of life, sickness, accident, or other benefits
exclusively to the members of such society, order, or association, or nonstock
corporation or their dependents;

(D) Cemetery company owned and operated exclusively for the benefit of its
members;

(E) Nonstock corporation or association organized and operated exclusively for

religious, charitable, scientific, athletic, or cultural purposes, or for the
rehabilitation of veterans, no part of its net income or asset shall belong to or
inure to the benefit of any member, organizer, officer or any specific person;

(F) Business league chamber of commerce, or board of trade, not organized for
profit and no part of the net income of which inures to the benefit of any private
stock-holder, or individual;

(G) Civic league or organization not organized for profit but operated exclusively
for the promotion of social welfare;

(H) A nonstock and nonprofit educational institution;

(I) Government educational institution;

(J) Farmers' or other mutual typhoon or fire insurance company, mutual ditch or
irrigation company, mutual or cooperative telephone company, or like
organization of a purely local character, the income of which consists solely of
assessments, dues, and fees collected from members for the sole purpose of
meeting its expenses; and

(K) Farmers', fruit growers', or like association organized and operated as a sales
agent for the purpose of marketing the products of its members and turning back
to them the proceeds of sales, less the necessary selling expenses on the basis
of the quantity of produce finished by them;

Notwithstanding the provisions in the preceding paragraphs, the income of

whatever kind and character of the foregoing organizations from any of their
properties, real or personal, or from any of their activities conducted for profit
regardless of the disposition made of such income, shall be subject to tax
imposed under this Code.
Chapter V - Computation of Taxable Income
Section 31 Taxable Income Defined

Chapter VI - Computation of Gross Income

Section 32 Gross Income
(A) General Definition
(B) Exclusions from Gross Income
Section 33 Special Treatment of Fringe Benefit
(A) Imposition of Tax
(B) Fringe Benefit Defined
(C) Fringe Benefits Not Taxable

Chapter VII - Allowable Deductions

Section 34 Deductions from Gross Income
(A) Expenses
(1) Ordinary and Necessary Trade, Business or Professional Expenses
(a) In General
(b) Substantiation Requirements.
(c) Bribes, Kickbacks and Other Similar Payments
(2) Expenses Allowable to Private Educational Institutions
(B) Interest
(1) In General
(2) Exceptions
(3) Optional Treatment of Interest Expense
(C) Taxes
(1) In General
(2) Limitations on Deductions
(3) Credit Against Tax for Taxes of Foreign Countries
(a) Citizen and Domestic Corporation
(b) Partnerships and Estates
(4) Limitations on Credit
(5) Adjustments on Payment of Incurred Taxes
(6) Year in Which Credit Taken
(7) Proof of Credits
(D) Losses
(1) In General
(2) Proof of Loss
(3) Net Operating Loss Carry-Over
(4) Capital Losses
(a) Limitations
(b) Securities Becoming Worthless
(5) Losses From Wash Sales of Stock or Securities
(6) Wagering Losses
(7) Abandonment Losses
(E) Bad Debts
(1) In General
(2) Securities Becoming Worthless
(F) Depreciation
(1) General Rule
(2) Use of Certain Methods and Rates
(3) Agreement as to Useful Life on Which Depreciation Rate is
Based
 (4) Depreciation of Properties Used in Petroleum Operations
(5) Depreciation of Properties Used in Mining Operations
(6) Depreciation Deductible by Nonresident Aliens Engaged in
Trade or Business or Resident Foreign Corporations
(G) Depletion of Oil and Gas Wells and Mines
(1) In General
(2) Election to Deduct Exploration and Development Expenditures
(H) Charitable and Other Contributions
(1) In General
(2) Contributions Deductible in Full
(a) Donations to the Government
(b) Donations to Certain Foreign Institutions or
International Organizations
(c) Donations to Accredited Nongovernment Organizations
(3) Valuation
(4) Proof of Deductions
(I) Research and Development
(1) In General
(2) Amortization of Certain Research and Development
Expenditures
(3) Limitations on Deduction
(J) Pension Trusts
(K) Additional Requirements for Deductibility of Certain Payments
(L) Optional Standard Deduction (OSD)
Section 35 Allowance of Personal Exemption for Individual Taxpayer
(REPEALED)
Section 36 Items not Deductible
Section 37 Special Provisions Regarding Income and Deductions of Insurance
Companies, Whether Domestic or Foreign
Section 38 Losses from Wash Sales of Stock or Securities
Section 39 Capital Gains and Losses
Section 40 Determination of Amount and Recognition of Gain or Loss
Section 41 Inventories
Section 42 Income from Sources Within the Philippines

Chapter VIII - Accounting Periods and Methods of Accounting

Section 43 General Rule
Section 44 Period In Which Items of Gross Income Included
Section 45 Period for Which Deductions and Credits Taken
Section 46 Change of Accounting Period
Section 47 Final or Adjustment Returns for a Period of Less than Twelve (12)
Months
Section 48 Accounting for Long-term Contracts
Section 49 Installment Basis
Section 50 Allocation of Income and Deductions

Chapter IX - Returns and Payment of Tax

Section 51 Individual Return
 Section 52 Substituted Filing of Income Tax Returns by Employees Receiving
Purely Compensation Income
Section 53 Corporate Returns
Section 54 Extension of Time to File Returns
Section 55 Returns of Receivers, Trustees in Bankruptcy or Assignees
Section 56 Returns of General Professional Partnerships
Section 57 Payment and Assessment of Income Tax for Individuals and
Corporations
Section 58 Withholding of Tax at Source
Section 59 Returns and Payment of Taxes Withheld at Source
Section 60 Tax on Profits Collectible from Owner or Other Persons

Chapter X - Estates and Trusts

Section 61 Imposition of Tax
Section 62 Taxable Income
Section 63 Exemption Allowed to Estates and Trusts
Section 64 Revocable Trusts
Section 65 Income for Benefit of Grantor
Section 66 Fiduciary Returns
Section 67 Fiduciaries Indemnified Against Claims for Taxes Paid

Chapter XI - Other Income Tax Requirements

Section 68 Collection of Foreign Payments
Section 69 Information at Source as to Income Payments
Section 70 Return of Information of Brokers
Section 71 Returns of Foreign Corporations
Section 72 Disposition of Income Tax Returns, Publication of Lists of Taxpayers
and Filers
Section 73 Suit to Recover Tax Based on False or Fraudulent Returns
Section 74 Distribution of Dividends or Assets by Corporations

Chapter XII - Quarterly Corporate Income Tax Annual Declaration

Section 75 Declaration of Income Tax for Individuals
Section 76 Declaration of Quarterly Corporate Income Tax
Section 77 Final Adjustment Return
Section 78 Place and Time of Filing and Payment of Quarterly Corporate Income
Tax

Chapter XIII - Withholding on Wages

Section 79 Definitions
Section 80 Income Tax Collected at Source
Section 81 Liability for Tax
Section 82 Filing of Return and Payment of Taxes Withheld
Section 83 Return and Payment in Case of Government Employees
Section 84 Statements and Returns