SyCipLaw’s Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S.) for May which covers the following tax issues:


  1. Is a Petition for Declaratory Relief with the Regional Trial Court ("RTC") the proper remedy to assail the validity of a Revenue Regulation ("RR")?
  2. May banks and other financial institutions that have foreign currency deposit units ("FCDU/EFCDU") deduct their common expenses in full against the income of their regular banking units ("RBU") that are subject to regular tax (i.e., without any allocation or attribution between the different income streams from the RBU, FCDU/EFCDU, or offshore banking unit ("OBU") operations)?
  3. Is the importation of alkylate subject to excise tax under Section 148(e) of the Tax Code? 
  4. May an enterprise within the Subic Special Economic Zone avail itself of the exemption from the payment of documentary stamp tax for a transaction that was entered into prior to the issuance of a Certificate of Registration and Tax Exemption in its favor?
  5. May a taxpayer avail itself of the benefits of the Tax Amnesty Act while the tax investigation against it is ongoing?
  6. What are the amendments introduced by RR No. 3-2023 to the regulations on VAT zero-rating?
  7. What are the requirements for a domestic corporation to avail itself of the income tax exemption under theTax Code on its foreign-sourced dividends?
  8. What are the supplemental guidelines for the transfer of registration of a Registered Business Enterprise ("RBE") in the Information Technology-Business Process Management ("IT-BPM") sector froman IPA to the Board of Investments ("BOI")?


Please read the full text here or via this link.