Income Taxation

General Principles

MGRT / January 18, 2024

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 Taxation
Taxation is the process by which the
sovereign, through its lawmaking
body, raises income to defray the
expenses of the government.

Taxation is a mode of raising

revenue for public purpose.

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 Thus:

a. Taxes are enforced contributions;

b. Taxes are proportional in character, since taxes are based on
one’s ability to pay;
c. Taxes are levied by authority of the law;
d. Taxes are for the support of the government and all its public
needs.

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 BASIS OF TAXATION
A. TAXATION AND THE LIFEBLOOD DOCTRINE

• The power of taxation is essential because the government can neither exist nor
endure without taxation. Taxes are the lifeblood of the government and their
prompt and certain availability is an imperious need. (Bull v. Unites States, 295 U.S. 247,
15 APTR 1069)
• Taxes are the lifeblood of the government and consequently, tax laws must be
faithfully and strictly implemented as they are not intended to be liberally
construed. (CIR v. Dash Engineering Philippines, Inc., 712 SCRA 347)

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 BASIS OF TAXATION
B. THEORIES ON TAXATION

1. Necessity Theory

2. Benefits-Protection Theory
: DOCTRINE OF SYMBIOTIC RELATIONSHIP

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 “Taxes are what we pay for civilized society. Without taxes, the government would be
paralyzed for lack of the motive power to activate and operate it. Here, despite the natural
reluctance to surrender part of one’s hard-earned income to the taxing authorities, every
person who is able to must contribute his share in the burden of running the government.
The government, for its part, is expected to respond in the form of tangible and intangible
benefits intended to improve the lives of the people and enhance their material and moral
values.

CIR v. Algue, Inc., 158 SCRA 17

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 NATURE OF THE POWER OF TAXATION

1. Taxation as an INHERENT ATTRIBUTE TO SOVEREIGNTY

2. Taxation as LEGISLATIVE IN CHARACTER

3. Taxation is SUBJECT TO CONSTITUTIONAL AND INHERENT FUNCTIONS

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 ASPECTS OF TAXATION
Power of taxation: SUPREME, ULIMITED and COMPREHENSIVE

1. LEVY / IMPOSITION - enactment of tax laws or statutes (See Tolentino, et

al. vs. Secretary of Finance, 235 SCRA 630)
2. ASSESSMENT AND COLLECTION
• Administrative in character, may be delegated
• FIRST: designate which agency will collect tax
• SECOND: circulars and regulations issued by the SOF or the CIR must
be in accordance with the tax measures imposed by Congress.
3. PAYMENT: compliance by the taxpayer.

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 “Taxes are what we pay for civilized society. Without taxes, the government would be
paralyzed for lack of the motive power to activate and operate it. Here, despite the natural
reluctance to surrender part of one’s hard-earned income to the taxing authorities, every
person who is able to must contribute his share in the burden of running the government.
The government, for its part, is expected to respond in the form of tangible and intangible
benefits intended to improve the lives of the people and enhance their material and moral
values.

Tolentino, et al. v. Secretary of Finance, 235 SCRA 630

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SCOPE OF LEGISLATIVE POWER TO TAX

1. The subjects to be taxed

2. The purpose of the tax
3. The amount or rate of the tax
4. The manner, means, and agencies of collection of tax
5. All other incidents of exercising the power

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 Discretion as to subjects of taxation

1. Unlimited scope to tax — PERSONS, PROPERTY or OCCUPATION

where there are no constitutional restrictions, provided, that the
property is within the territorial jurisdiction of the taxing state.

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 It is not for the courts to judge what particular cities or
municipalities should be empowered to impose occupation taxes
in addition to those imposed by the National Government. The
matter is peculiarly within the domain of the political
departments and the courts would do well not to encroach upon
it.

Silvestre Punsalan v. The Municipal Board of the City of Manila, 95 Phil. 46

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 Discretion as to purpose of tax

• The Sole Arbiter of the purposes for which taxes shall be levied is the
LEGISLATURE, provided that purposes are public.
• Courts may review the levy of the tax to determine whether the
purpose is a public one.

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The Legislature may determine within reasonable bounds what is
necessary for its protection and expedient for its promotion.
Here, the legislative discretion must be allowed full slay, subject
only to the test of reasonableness; and it not contended that the
means provided in Sec. 6 of CA No. 567 bear in character.

Walter Lutz v. Antonio Araneta, 235 SCRA 630

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 Discretion as to amount or rate of tax

• The Legislature has the right to finally determine the amount or rate
of a tax, in the absence of constitutional prohibitions.
• Not only is the power to tax unlimited in its reach as to subjects, but
in its very nature, it acknowledges no limits and may be carried even
to the extent of exhaustion and destruction, thus becoming in its
exercise a power to destroy.

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 … manner, means, and agencies of collection of
tax

• The discretion of the Legislature extend to the MODE, METHOD or

KIND of tax.
• As to Kind of taxes, the Legislature has the power to levy one or
more of the following:
• Property Tax, Excise Tax, License or Occupation Tax, Poll or
Capitation tax, franchise tax, income tax, stock transfer tax

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All other incidents of exercising the power

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 Q: Is the power to tax the power to destroy?

A: Justice Malcolm believed that the power to tax “is an attribute of

sovereignty. It is the strongest of all the powers of the government.

Chief Justice Marshall of the U.S. Supreme Court declared that: “The
power to tax involves the power to destroy.”

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 However, instead of being regarded as a blanket authorization of the
unrestrained use of the thing power for any and all purposes, it is
more reasonable to say that the maxim “the power to tax is the power
to destroy” is to describe not the purposes for which taxing power may
be used but the degree of vigor with which the taxing power may be
employed in order to raise revenue.

1 Cooley, 179 - 181

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 The power of taxation is sometimes called also the power to
destroy. Therefore it should be exercised with caution to minimize
injury to the propriety rights of a taxpayer. It must be exercised
fairly, equally and uniformly, lest the tax collector kill the ‘hen that
lays the golden egg.’”

Roxas, et al. v. CTA, et al.

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 JUDICIAL REVIEW OF TAXATION

The power to tax is not the power to destroy while the

Supreme Court sits. While taxation is said to be the power to
destroy, it is by no means unlimited.

Roxas, et al. v. CTA, et al.

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 BASIC PRINCIPLES OF A SOUND TAX
SYSTEM

1. FISCAL ADEQUACY
2. EQUALITY OR THEORETICAL JUSTICE
3. ADMINISITRATIVE FEASIBILITY

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 FISCAL ADEQUACY

Every tax ought to be contrived as both to take out and to keep out
of the pockets of the people as little as possible over and above
what it brings into the public treasury of the State.

The Wealth of Nations, Book V, Chapter II

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 THEORETICAL JUSTICE

Taxation is said to be equitable when its burden falls on those

better able to pay; taxation is progressive when its rate goes up
depending on the resources of the person affected.

The Constitution of the Philippines, Fernando, 2nd Ed., p. 221

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 ADMINISTRATIVE FEASIBILITY

The law is principally aimed to rationalize the system of taxes on

goods and services; simplify tax administration, and make the
system more equitable to enable the country to attain economic
recovery.

Kapatiran Ng Mga Naglilingkod sa Pamahalaan v. Tan, 163 SCRA 371

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 CLASSIFICATION OF TAXES

1. As to subject. Manner or object

2. As to who bears the burden
3. As to determination of amount
4. As to purpose
5. As to authority imposing the tax
6. As to graduation or rate

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 1. As to subject matter or object

A. Personal, poll, or capitation

B. Property
C. Excise

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 2. As to who bears the burden

A.Direct
B.Indirect

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 3. As to determination of amount

A. Specific
B.Ad Valorem

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 4. As to purpose

A.General, fiscal, or revenue

B. Special or regulatory

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 5. As to taxing authority

A. National
B. Municipal or local

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 6. As to graduation or rate

A. Proportional
B. Progressive or graduated
C. Regressive

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Taxation Distinguished from other INHERENT POWERS
Taxation vs. Police Power

Taxation Police Power

Promote public welfare through

Purpose Primarily: To Raise Revenue
regulation

Limited to the cost of regulation,

Amount of Exaction Contemplates No limits
issuance of the license, or surveillance

Benefits Received
No special or direct benefit No special or direct benefit
by the Taxpayer

Superiority of Recognized that obligations imposed

Does not apply to Police Power
Contract by contracts

Transfer of Property Merely allows the restraint on the

Paid from part of the public funds
Rights exercise of property rights.

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Taxation Distinguished from other INHERENT POWERS
Taxation vs. Power of Eminent Domain

Taxation Police Power

Tust compensation is give the owner of

Purpose Primarily: To Raise Revenue
the expropriated property

Only a particular property is being

Person Affected All persons, property and excises
contemplated

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 Taxation Distinguished from other
Impositions
Tax vs. License

Tax License

Emanate from the police power of the

Levied on: The Taxing power
state

Purpose Generate revenues Imposed for regulatory purposes

Regulation is the primary purpose,

Regulation is merely incidental
incidental revenue is also obtained

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 Taxation Distinguished from other
Impositions
Tax vs. Toll

Tax Toll

Demand of proprietorship, an amount

As to the kind of Demand of sovereignty for the
charged for the cost and maintenance of
charged purpose of raising public revenues
the property used.

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Taxation Distinguished from other
Impositions
Taxation vs. Penalty

Tax Penalty

Criminal liability for the commission of a

What? Civil Liability
crime

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 Taxation Distinguished from other
Impositions
Tax vs. Debt

Tax Debt

Not contracts b/n the parties, Criminal liability for the commission of a
What
POSITIVE ACTS of the gov’t crime

Can it be assigned? No. Yes.

Can it be made
No. Yes.
subject of set-off?

Can it be prescribe? No Yes.

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 LIMITATIONS ON THE TAXING POWER
INHERENT LIMITATIONS ON THE POWER TO TAX

1. Public Purpose
2. International Comity
3. Territoriality
4. Non-Delegation of the Power to Tax
5. Exemption from Taxation of Government Agencies/
Instrumentalities

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 PUBLIC PURPOSE

1. Taxes are exacted only for a public purpose

2. Who may determine “public purpose”
3. Purpose when deemed “public”

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 PUBLIC PURPOSE

1. Taxes are exacted only for a public purpose

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 Who may determine “public purpose”

1. This is a legislative prerogative.

2. The power to determine whether the purpose of taxation is public
or private resides in the Congress.
3. This will not prevent the court from questioning the propriety of
such a statue on the ground that the law enacted is not for a public
purpose.

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 When Deemed “PUBLIC”

1. The purpose NOT the number of persons benefited.

2. Ultimately: if the result FAVORS the welfare of the public in
general, the appropriation of a public revenue is deemed done for
a public purpose.
3. CIR v. Central Luzon Drug Corporation, 456 SCRA 414

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 Some cases of “Public Purpose”
1. Public Improvement
2. Unemployment relief
3. Buildings and roads/ infrastructure
4. Local police force
5. Construction of home sites
6. Promotion of science and invention
7. Upliftment of the underprivileged
8. Rehabilitation of the sugar industry
9. Pension to deserving retirees
10. Oil industry’s protection
11. Socialized housing
12. Educational subsidy

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 2. International Comity
• Basis of this Rule. Section 2, Article II of the 1987 Constitution

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 3. Territoriality
• Since law cease to operate beyond a country’s jurisdictional limits,
the taxing power of a country is likewise limited to person and
property w/in and subject to its jurisdiction.

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 4. Non-Delegation of the Power to Tax
• The power to tax is exclusively vested in the legislative body.
• XPN: Art. VI, Section 28(2) of the Constitution
• The Congress may, by law, authorize the President to impose
tariff rates, import and export quotas, custom duties, subject
to the limitations and guidelines as the Congress may impose
• Art. X, Section 5 of the Constitution

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 5. Exemption from Taxation of Government Agencies/
Instrumentalities.

• Properties of the National Government as well as those of the local

government units are not subject to tax, otherwise it will result in the
absurd situation where the government “taking money from one
pocket and putting it in another”
• Agencies performing governmental functions and proprietary
functions distinguished
• As a rule, agencies performing governmental functions are tax-
exempt unless expressly taxed. Agencies performing proprietary
functions are subject to tax unless expressly exempted.
• GOCC (Government-owned and controlled corporations)

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 LIMITATIONS ON THE TAXING POWER
Constitutional Limitations on the Power to Tax

1. Due Process of the Law

2. Equal Protection of laws
3. Uniformity
4. Progressive system of taxation
5. Non-impairment of contracts
6. Non-imprisonment for non-payment of poll tax
7. Appropriation, revenue and tariff bills must originate exclusively in the House of Representatives
8. Presidential Veto
9. Presidential power to fix tariff rates
10. Freedom of the press
11. Freedom of religion

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 1. DUE PROCESS OF THE LAW

• No Person shall be deprived of life, liberty or property without due process of the
law… (Art. III, Section 1, 1987 Constitution)
Notice and Hearing.
• It may be invoked where a taxing statute is SO ARBITRARY that if finds no
support in the Constitution, as where it can be shown to amount to confiscation
of property.

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 DUE PROCESS OF THE LAW
Requiring a person before he can be employed to get a permit from the City Mayor of
Manila who may withhold or refuse it at will is tantamount to denying him the basic right
to engage in a means of livelihood. While it is true that the Philippines as a state is not
obliged to admit aliens within it s territory, once an alien is admitted, he cannot be
deprived of life without due process of law. This guarantee includes the means of
livelihood. The shelter of protection under the due process and equal protection clause is
given to all persons, both aliens and citizens.
(Mayor Antonio Villegas v. Hiu Chiong Tsai Pao Ho, 86 SCRA 270)

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 DUE PROCESS OF THE
(EXAMPLES)

1. If the tax amounts to confiscation of property

2. If the subject of confiscation is outside the jurisdiction of the taxing
authority
3. If the law is imposed for a purpose other than a public purpose
4. If the law w/c is applied retroactively imposes unjust and
oppressive taxes
5. Where the law is in violation of inherent limitations

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 2. EQUAL PROTECTION OF THE LAW

…Nor shall any person be denied the equal protection of the law. (Art. III, Sec. 1)
Uniformity NOT Equality
Equal protection does not require equal rates of taxation on different classes of property,
nor prohibit unequal taxation so long as the inequality is not based upon arbitrary
classification.

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 EQUAL PROTECTION OF THE LAW

All persons subjected to such legislation shall be treated alike, under like
circumstances and conditions, both in the privileges conferred and in the
liabilities imposed.
(Cooley Taxation, 534 - 535)

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 EQUAL PROTECTION OF THE LAW

Absolute Equality Impossible.

Practical equality is constitutional Equality

“Perfect equality in taxation will remain an unattainable goal as

long as laws and government and man are imperfect.”

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 EQUAL PROTECTION OF THE LAW

The equal protection clause does not require the universal application of
the laws on all persons or things without distinction. This might in fact
sometimes result in unequal protection. What the clause requires is
equality among equals as determined according to a valid classification.
By classification is meant that grouping of persons or things similar to
each other in certain particulars and different from all others in these
same particulars.
(Abakada Guro Party List vs. Ermita, 469 SCRA 1)

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 EQUAL PROTECTION OF THE LAW
For Classification to be valid, the following must concur:

It must be based on substantial distinction;

It must apply both to present and future
conditions;
It must be germane to the purpose of the law;
It must apply equally to all members of the same
class.

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 3. UNIFORMITY OF TAXATION

“The rule of taxation shall be uniform and equitable” (Art. VI, Sec. 28(1), 1987 Constitution
tax is uniform when it operates with the same form and effect in every
A

place where the subject of it is found.

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 3. UNIFORMITY OF TAXATION
Equality vs. Uniformity
Equality: when the burden of tax falls equally and impartially upon
all the person and property subject to it.
Uniformity: all taxable property shall be alike subjected to the tax
“A tax is considered uniform when it operates with the same force
and effect in every place where the subject may be found.”

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 4. PROGRESSIVE TAXATION

Congress shall evolve a progressive system of taxation. (Art. VI, Sec.

28(1))
Principle: Taxpayer’s ability to pay.

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 5. NON-IMPAIRMENT OF CONTRACT

No law shall be passed impairing the obligations of contract. (Art.

III, Sec. 10, 1987 Constitution)
Contract is the law b/n the contracting parties.
Any law — enlarges, changes the intention of the parties — IMPAIRS
THE CONTRACT.
When the government sheds off its immunity by acting in a private
capacity in entering into a contract to private individuals/entities.

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6. NON-IMPRISONMENT FOR NON-PAYMENT OF POLL TAXES

No person shall be imprisoned for non-payment of a debt or poll

tax. (Art. III, Sec. 20)
Poll Taxes
May still be imprisoned for non-payment of OTHER KINDS OF
TAXES where the law so expressly provides.

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 7. TAXATION AND THE FREEDOM OF THE
PRESS

Tolentino vs. Secretary of Finance, 235 SCRA 630

PPI claimed violation of their Bill of Rights because of the tax
imposed against them per the enacted of the VAT Law.
WON there has been a violation of their Constitutional Right?
No. A publisher has no immunity from the general regulation
of the State.

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8. TAXATION AND FREEDOM OF RELIGION

No law shall be made respecting an establishment of

religion or prohibiting the free exercise thereof. The free
exercise and enjoyment of religious profession and
worship without discrimination or preference shall forever
be allowed. No religious test shall be required for the
exercise of civil or political rights. (Art. III, Sec. 5, 1987
Constitution)

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 ACTUALLY, DIRECTLY AND EXCLUSIVELY USED FOR RELIGIOUS,
CHARITABLE AND EDUCATIONAL PURPOSES

American Bible Society vs. City of Manila

A municipal tax on the sale of bibles and religious
articles by a non-stock, non-profit missionary
organization at minimal profit constitutes a
curtailment of religious freedom and worship w/c is
guaranteed by the Constitution.

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 FREEDOM OF RELIGION

Charitable institutions, churches, and parsonages or convents

appurtenant thereto, mosques, non-profit cemeteries, and all
lands, buildings and improvements ACTUALLY, DIRECTLY and
EXCLUSIVELY used fro religious, charitable or educational
purposes shall be exempt from taxation. (Art. VI, Sec. 28(3), 1987
Constitution)
To be exempt: Charitable Institutions — Test of Charity

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 ACTUALLY, DIRECTLY AND
EXCLUSIVELY
ACTUALLY: opposite of seemingly, pretendedly, or
resignedly
DIRECTLY: without anything intervening not by secondary,
but by direct means
EXCLUSIVELY: Apart from all others
Extends to facilities w/c are incidental to and reasonably necessary for
the accomplishment of the MAIN GOAL

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9. NON-STOCK, NON-PROFIT EDUCATIONAL INSTITUTION

(Sec. 4 (3)) All revenues and assets of non-stock, non-profit

educational institutions used actually, directly and
exclusively for education purposes shall be exempt from
taxes and duties.
LITERAL INTERPRETATION: SOLELY
Exclusive: is defined as possessed and enjoyed to the
exclusion of others.

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9. NON-STOCK, NON-PROFIT EDUCATIONAL INSTITUTION

Art. XIV, Sec. 4 (3) Art. VI, Sec. 28(3)

Non-stock, Non-profit educational Religious, educational,

Grantee:
institution charitable

Income Tax
Taxes Covered: Custom Duties Property Tax
Property Tax

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 GRANT OF TAX EXEMPTIONS

Constitution
By an Act of the Legislature

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 GRANT OF TAX EXEMPTIONS

No law granting any tax exemption shall be passed

without the concurrence of a majority of all the members
of the Congress. (Art. VI, Sec. 28(4), 1987 Constitution)
Requires the ABSOLUTE MAJORITY of the Members of Congress
GR: NO EXEMPTION
XPN: Valid if they do not exceed the constitutional limits, and VOID if they do

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 Tax Exemption vs. Tax Amnesty

Tax Amnesty: immunity from criminal and civil

liability arising from non-payment of taxes.
Tax Exemption: immunity from civil liability only

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 LOCAL TAXATION

Each local government unit shall have the power to create its own
sources of revenues and to levy taxes, fees and charges subject to
such guidelines and limitations as the Congress may provide,
consistent with the basic policy of local autonomy. Such taxes,
fees, and charges shall accrue exclusively to the local
governments. (Art. X, Sec. 5, 1987 Constitution)
R.A. 7160 (Local Government Code)

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 SUPREME COURT’S JURISDICTION OVER TAX CASES

The SC shall have the following powers:

Review, revise, reverse, modify or affirm on appeal or certiorari as the
law or the Rules of Court may provide, final judgments or orders of lower
courts in:
(b) All cases involving the legality of any tax, imposed, assessment or
toll, or any penalty imposed in relation thereto.
(Art. VIII, Sec. 5)

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 Tax Evasion vs. Tax Avoidance

Tax evasion: fraud, forbidden devices to lessen or

defeat taxes
Tax avoidance: legal means to reduce taxes

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INCOME TAXATION

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 DEFINITION AND NATURE OF INCOME
TAX
1. INCOME TAX — tax on all yearly profit arising from property,
professionals, trades or offices, or as a tax on a person’s
income, emoluments, and profits.
2. Income tax is generally regarded as an excise tax. It is not levied
upon persons, property, funds, or profits but upon the right of a
person to receive income or profits.

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 POWER TO IMPOSE INCOME TAX

1. INCOME TAX — tax on all yearly profit arising from property,

professionals, trades or offices, or as a tax on a person’s
income, emoluments, and profits.
2. Income tax is generally regarded as an excise tax. It is not levied
upon persons, property, funds, or profits but upon the right of a
person to receive income or profits.

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 FUNCTION OF INCOME TAX

1. To provide revenues
2. To mitigate the evils arising from the inequalities in the
distribution of income and wealth w/c is considered deterrents to
social progress, by a progressive scheme of taxation.

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SITUS OF INCOME FOR TAX PURPOSES

A. Nature of the tax and the subject matter thereof (person,

property, act, or activity)
B. The possible protection and benefit that may accrue both to the
government and to the taxpayer
C. Domicile or residence
D. Citizenship;
E. Source of income.

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 INCOME DERIVED WITHIN THE STATE
TAXABLE
• A state can tax all income derived from sources w/in the State,
whether or not the recipient is a citizen, a resident, or a non-
resident, or a domestic, or foreign corporation.
• The term “source” is not a place but the property, activitY, or service
that produced the income.

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 HISTORY OF PHILIPPINE INCOME TAX
LAW
1. REVENUE ACT OF 1913
2. Revenue Act extended to the Philippines
3. Revenue Act of 1916
4. War Revenue Act of 1917
5. Act No. 2833 (Philippine Legislature)
6. Act No. 2926, 3026, 3605 and 3671
7. Commonwealth Act No. 466 - National Internal Revenue Code (Title II - Income Taxation)
8. 1939 National Internal Revenue Code
9. Republic Act No. 6110 (Omnibus Tax Law)
10. Presidential Decree No. 69
11. National Internal Revenue Code of 1977
12. National Internal Revenue Code of 1986
1. P.D. 1994, EO 273, RA. No. 8424, 8761, 9010, 9238, 9243, 9294, 9334, 9337, 9361, 9054, 9648, 10001,010378, 10653, 10963 (TRAIN Act), 11256 and 11534
(Corporate Reform and Incentives for Enterprises [CREATE ACT])

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 THE BUREAU OF INTERNAL REVENUE
1 Commissioner of Internal Revenue

4 Deputy Commissioners

Department of Finance

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 THE BUREAU OF INTERNAL REVENUE
GENERAL POWERS AND DUTIES

A. To assess and collect all national internal revenue taxes, fees, and charges;
B. To enforce all forfeitures, penalties, and fines connected therewith;
C. To execute judgments in all cases decided in its favor by the CTA and
ordinary courts
D. To give effect to and administer the supervisory and police power
conferred to it by law
E. To recommend to the SOF all needful rules and regulations for the
effective enforcement of the Tax Code (Sec. 244, NIRC)

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 THE BUREAU OF INTERNAL REVENUE
OTHER FUNCTIONS

A. Accounting for all revenues collected;

B. Exercising all legal requirements that are appropriate
C. Preventing and prosecuting tax evasions and illegal activities
D. Exercising supervision and control over its constituents
E. Performing such other functions as provided by law (Sec. 28, E.O.
127)

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 SOURCES OF OUR LAW ON INCOME
TAXATION

A. Constitution
B. Statutes
C. The Tax Regulations
D. Administrative rulings and opinions
E. Judicial Decisions
F. Tax Treaties with other countries

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 Sources: Constitution

A. Art. III, Sec. 1, 5, 10, 20

B. Art. VI, Sec. 27(2), 28(1, 3, and 4); Sec. 29(2)
C. Art. VIII, Sec. 5 (2, b)
D. Art. XIV, Sec. 4(3, 4)

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 Sources: Statutes

A. R.A. 8424, amended by TRAIN and CREATE LAW, Title II of the

Tax Code, Chapters I to XI, from Section 22 to Section 83

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 Sources: Income Tax Regulations

A. Section 244 of the Tax Code

B. SOF promulgated under his rule making power, Rev. Reg. No. 2 (as
amended)
C. Income Tax Regulations

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 Sources: Income Tax Regulations

A. R.A. 8424, amended by TRAIN and CREATE LAW, Title II of the

Tax Code, Chapters I to XI, from Section 22 to Section 83

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 Sources:
OTHER FUNCTIONS

A. Accounting for all revenues collected;

B. Exercising all legal requirements that are appropriate
C. Preventing and prosecuting tax evasions and illegal activities
D. Exercising supervision and control over its constituents
E. Performing such other functions as provided by law (Sec. 28, E.O.
127)

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