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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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