Tax Updates September 2022 (SyCipLaw Tax Issues and Practical Solutions (T.I.P.S.) International Edition Vol. 7)
October 17, 2022
SyCipLaw's Tax Department has prepared an international edition of its Tax Issues and Practical Solutions (T.I.P.S.) for the third quarter of 2022.
The SyCipLaw T.I.P.S - International Edition covers the following tax issues:
1. Is a holding company considered a non-bank financial intermediary ("NBFI") liable for local business taxes imposed by a city?
2. Does the failure to file an application for tax treaty relief under Revenue Memorandum Order ("RMO") No.1-2000 automatically bar the taxpayer from subsequently availing of such benefits?
3. Does the Commissioner of Internal Revenue have a fresh or separate 180-day period to decide an administrative appeal (that is, a request for reconsideration of the denial by a representative of the Commissioner, of a taxpayer's protest against a tax assessment)?
4. Is a Certificate of Compliance from the Energy Regulatory Commission required for the availment of zero-rated Value Added Tax ("VAT") for sales of electricity and generation services?
5.1 Has the suspension of tax audits and other field operations been lifted?
5.2 Has the suspension of the conduct of enforcement and other field operations covered by outstanding mission orders ("MOs") and the prohibition on the issuance of new MOs been lifted?
6. Are all receipts/invoices covered by the removal of the five (5)-year validity period on receipts/ invoices under Revenue Regulations ("RR") No. 6-2022 dated June 30, 2022?
7. May a Philippine corporation change the tax accounting treatment of certain of its assets, i.e., from inventory to fixed assets, to align with its foreign parent company's policy?
8. Can a foreign corporation with tax residence in Hungary invoke the most-favored-nation ("MFN") clause under the Philippines-Hungary Tax Treaty and claim the lowest rate provided for royalties under the Philippines-United Arab Emirates ("UAE") Tax Treaty?
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