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Tax Amnesty Ruling: CIR vs. Transfield

Transfield Philippines received notices of deficiency income tax, expanded withholding tax, and value-added tax for fiscal years 2001 to 2002. The Commissioner of Internal Revenue issued a warrant of distraint and/or levy against Transfield. The Court of Tax Appeals declared the warrant null and void. The issue was whether Transfield was entitled to immunities under the Tax Amnesty Program. The Supreme Court ruled yes, as Transfield complied with all requirements of the tax amnesty by submitting the proper forms and paying the amnesty taxes, so the deficiency taxes for 2001 to 2002 were deemed settled.

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1K views1 page

Tax Amnesty Ruling: CIR vs. Transfield

Transfield Philippines received notices of deficiency income tax, expanded withholding tax, and value-added tax for fiscal years 2001 to 2002. The Commissioner of Internal Revenue issued a warrant of distraint and/or levy against Transfield. The Court of Tax Appeals declared the warrant null and void. The issue was whether Transfield was entitled to immunities under the Tax Amnesty Program. The Supreme Court ruled yes, as Transfield complied with all requirements of the tax amnesty by submitting the proper forms and paying the amnesty taxes, so the deficiency taxes for 2001 to 2002 were deemed settled.

Uploaded by

Nivra Lyn Empiales
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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CIR vs. Transfield Philippines, Inc.

,
G.R. No. 211449, January 16, 2019

FACTS:
Transfield Philippines, Inc. received copies of Final Assessment Notice (FAN)
issued by Commissioner of Internal Revenue (CIR) for deficiency income tax,
Expanded Withholding Tax (EWT), and Value-Added Tax (VAT) for the Fiscal
Year 2001 to 2002. CIR issued a Warrant of Distraint and/or Levy (WDAL)
against Transfield. CTA First Division declared WDAL as null and void, which was
affirmed by CTA En Banc.

ISSUE:
WON Transfield is entitled to the immunities under the Tax Amnesty Program
provided in R.A. No. 9480?

RULING:
Yes. In this regard, Transfield complied with all the requirements pertaining to its
application for tax amnesty by submitting to the BIR a Notice of Availment of Tax
Amnesty, Tax Amnesty Return, SALN as of December 31, 2005, and Tax
Amnesty Payment Form. Further, it paid the corresponding amnesty taxes. Thus,
the deficiency taxes for Fiscal Year 2001 to J2002 are deemed settled in view of
respondent's compliance with the requirements for tax amnesty under R.A. No.
9480.

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