Year-End Tax Updates and Compliance

The content of this webinar includes relevant BIR regulations and memorandum orders; and Court of Tax Appeals and Supreme Court rulings covering the year 2025 (up to November). The topics are easily arranged based on the practical issues as it is encountered by the taxpayers. The outline will be updated as new regulations and rulings are released and made available to the public.

INCOME TAX

1. This further amends the “De Minimis” benefits provisions of RR No. 2-98, as amended, increasing Clothing Allowance pursuant to RA No. 11975, the Fiscal Year 2024 General Appropriations Act, and Employees Achievement Awards (Revenue Regulations No. 04-2025, January 30, 2025)
2. This implements the amendments to Secs. 27, 28, and 34 of the NIRC, as amended by RA No. 12066 (Revenue Regulations No. 07-2025, February 27, 2025)
3. This implements the amendments introduced by RA No. 12214 (Capital Markets Efficiency Promotion Act) on some sections of the Tax Code in relation to income (Revenue Regulations No. 21-2025, August 05, 2025)
4. Whether CTA En Banc correctly ordered the refund of the company’s allegedly deficiency income tax due to lack of due process, absence of a valid tax liability, and timely filing of the claim (Stradcom Corp. vs. CIR, G.R. No. 255520, April 21, 2025)
5. Whether the cooperative is liable for income tax, expanded withholding tax, and other taxes due to non-renewal of its Certificate of Tax Exemption (CCT Multi-Purpose Cooperative. vs. CIR, CTA EB No. 10351, June 24, 2025)
6. Whether the company is entitled to a refund or tax credit for income taxes paid on its gaming revenues claimed to be exempt under PAGCOR’s franchise (Bloomberry Resorts Corporation vs. CIR, CTA EB No. 2933, August 06, 2025)

VAT-EXEMPT & VATABLE TRANSACTIONS

1. This prescribes the policies and guidelines for the implementation of RA No. 12023 entitled “An Act Amending Sections 105, 108, 109, 110, 113, 114, 115, 128, 236 and 288 and Adding New Sections 108-A and 108-B of NIRC of 1997, as amended,” imposing VAT on Digital Services (Revenue Regulations No. 03-2025, January 17, 2025)
2. This implements pertinent provision of Sec. 295(D) of NIRC, as amended by Sec. 18 of RA No. 12066, particularly on the treatment of Local Sales of Goods and/or Services by Registered Business Enterprises (RBEs) (Revenue Regulations No. 09-2025, February 27, 2025)
3. This amends the pertinent provisions of RR No. 16-2005 to implement the VAT provisions under Secs. 106, 108, 109, and 112 the NIRC, as amended by RA No. 12066 (Revenue Regulations No. 10-2025, February 27, 2025)

4. This amends Sec. 14 of RR No. 03-2025 on the Implementation of RA No. 12023 (Revenue Regulations No. 14-2025, April 25, 2025)
5. Commencement of the 120-day period for the BIR to act on VAT refund claim (Doehle Shipmanagement Phils. vs. CIR, G.R. No. 246379, February 2025)
6. Whether the Dept. of Finance and BIR issuances excluding Domestic Market Enterprises from VAT zero-rating are valid, and whether the Regional Trial Court had jurisdiction to hear the petition (Subic Bay Freeport Champer of Commerce, Inc. vs. Dept. of Finance, et. al., G.R. No. 266016, February 04, 2025)
7. Whether the company is entitled to a refund of its unutilized VAT attributable to its zero-rated export sales (Coral Bay Nickel Corporation vs. CIR, G.R. Nos. 251333-34, March 05, 2025)
8. Whether a VAT-exempt entity such as Melco claim a refund for Input VAT mistakenly charged by suppliers (Melco Resorts Leisure Corp. vs. CIR, G.R. No. 271261, April 02, 2025)
9. Whether the company is entitled to avail of the VAT incentive granted under the Renewable Energy Law (CBK Power Co. Ltd. Vs. CIR, CTA EB No. 2801, January 17, 2025)
10. Whether Pacific Plaza Condominium Corp. is entitled to a refund representing alleged erroneously paid VAT on condominium dues for 2017 (Pacific Plaza Condominium Corp. vs. CIR, CTA EB No. 2769, March 18, 2025)
11. Whether the company substantiated that its clients were qualified non-resident foreign corporations and that the services were performed justifying a zero-rated VAT refund (BSM Crew Service Centre Phils., Inc., vs. CIR, CTA EB No. 2788, Mar. 25, 2025)
12. Whether the company is entitled to a refund of unutilized Input VAT for its alleged zero-rated sales (PPD Pharmaceutical Dev’t. Phils. Corp. vs. CIR, CTA EB No. 2839, April 03, 2025)
13. Whether the company was entitled to a refund or issuance of a tax credit certificate for Input VAT attributable to its zero-rated sales (Monte Solar Energy, Inc. vs. CIR, CTA EB No. 2919, Apr. 15, 2025)
14. Whether OceanaGold is entitled to a refund or tax credit of its claimed unutilized Input VAT (OceanaGold Phils., Inc. vs. CIR, CTA EB No. 2876, May 09, 2025)
15. Whether or not Petitioner is entitled to its claim for refund for alleged excess unutilized Input VAT (Pure Essence International, Inc. vs. CIR, CTA No. 10932, May 16, 2025)
16. Whether the company is entitled to a refund of unutilized Input VAT attributable to its alleged zero-rated sales of services (Avaloq Philippines Operating Headquarters vs. CIR, CTA EB No. 2897, June 03, 2025)
17. Whether the petitioner is entitled to a refund of Input VAT attributable to zero-rated services (Air Drilling Associates Pte. Ltd. vs. CIR, CTA No. 10609, July 03, 2025)
18. Whether the taxpayer is entitled to refund or tax credit certificate for its claimed unutilized Input VAT based on its zero-rated sales (Nippon Express Phils. Corp. vs. CIR, CTA EB No. 2875, July 14, 2025)
19. Whether the CTA Division had jurisdiction to hear the company’s claim for refund of unutilized Input VAT, considering BIR’s inaction on the administrative claim (Citco Int’l. Support Services, Ltd. – Phil. ROHQ vs. CIR, CTA EB No. 2900, August 07, 2025) 

20. Whether the company is entitled to a refund or tax credit of its unutilized Input VAT attributable to zero-rated sales (3M Phils., Inc. vs. CIR, CTA EB No. 2872, August 20, 2025)

WITHHOLDING TAX

1. This implements the tax provisions of RA No. 9267, otherwise known as “The Securitization Act of 2004.” (Revenue Regulations No. 02-2025, January 08, 2025)
2. This amends RR No. 2-98 relative to the Withholding Tax Rates on Certain Income Payments subject to Creditable Withholding Tax pursuant to Sec. 57 of NIRC (Revenue Regulations No. 05-2025, February 27, 2025)
3. This further amends Sec. 2.57.2(I) of RR No. 2-98, as amended by RR No. 11-2018, on the imposition of creditable withholding tax for top withholding agents (Revenue Regulations No. 24-2025, September 25, 2025)
4. This amends certain provisions and procedures under RMO No. 25-2024 in the processing of Tax Credit or Refund of Excess/ Unutilized Creditable Withholding Taxes (CWT) on Income (Revenue Memorandum Order No. 8-2025, February 19, 2025)

EXCISE TAX

1. This further amending Sec. 9 of RR No. 25-2003 relative to requirements to be submitted by Motor Vehicle Manufacturer/ Assembler/ Importer as basis to determine whether automobiles subject to Excise Tax exemption are hybrid or purely electric vehicles pursuant to RA No. 10963 (TRAIN Law) (Revenue Regulations No. 01-2025, January 06, 2025)
2. This implements Sec. 135 on Petroleum Products sold to International Carriers and Exempt Entities or Agencies and the new Sec. 135-A on Refund of Excise Tax on Petroleum Products of NIRC, as amended by RA No. 12066 (Revenue Regulations No. 06-2025, February 27, 2025)
3. This amends Secs. 3 & 4 of RR No. 16-2024 to update the prescribed floor of cigarettes, heated tobacco products, and vapor products (Revenue Regulations No. 17-2025, July 18, 2025)
4. This amends RR No. 25-2003, as amended, in relation to RR No. 5-2018, mainly for the purpose of removing pick-ups from the list of tax-exempt automobiles (Revenue Regulations No. 18-2025, August 05, 2025)
5. This implements the tax subsidy granted by Fiscal Incentives Review Board with respect to their purchases from local manufacturers subject to Excise Tax and the sale to persons entitled to commissary privileges (Revenue Regulations No. 23-2025, September 03, 2025)
6. This amends Sec. 8 of RR No. 25-2003 on the tax treatment on subsequent sale, transfer or exchange of tax-exempt automobile by a tax-exempt person/ entity to a non-exempt person/ entity (Revenue Regulations No. 27-2025, October 21, 2025)
7. Whether the company is entitled to refunds or tax credits for excise taxes paid during its recovery period under the Financial or Technical Assistance Agreement FTAA) (OceanaGold (Phils.) Inc. vs. CIR, CTA EB No. 2815, January 03, 2025)
8. Whether the Court in Division erred in dismissing the Petition for Review for the petitioner’s claim for refund of excise taxes (Philippine Airlines vs. CIR, CTA EB No. 2811, January 24, 2025)

9. Whether the company’s cologne products are subject to excise tax as “toilet waters” under Sec. 150 (b) of the NIRC (Green Cross, Inc. vs. CIR, CTA EB No. 2912, March 03, 2025)
10. Whether the company is entitled to a refund or tax credit of the excise taxes paid on its imported alkylate, on the ground that it is not subject to excise tax under Sec. 148(e) of the NIRC (Petron Corporation vs. CIR, CTA EB No. 2894, August 01, 2025)

CUSTOMS DUTY/ INDIRECT TAX

1. Whether the Bureau of Customs validly imposed the 40% duty rate on Mechanically Deboned Meat imports through Customs Memorandum Circular No. 131-2019 (Fabrossi Food Group, Inc. et. al. vs. Bureau of Customs, CTA EB No. 2742, February 28, 2025)

ESTATE TAX

1. This amends certain provisions of RR No. 6-2019 to provide extension on the period of submission of Documentary Requirements for Estate Tax Amnesty availment (Revenue Regulations No. 16-2025, June 24, 2025)

LOCAL BUSINESS TAX

1. Whether the company is entitled to a refund of Local Business Tax paid for the 3^rd and 4^th quarters of 2015 (Casas + Architects vs. City of Makati, CTA EB No. 2771, January 27, 2025)
2. Whether the Court of Tax Appeals has jurisdiction to review the RTC’s decision involving both Local Business Tax and regulatory fees (Bellagio Two Condominium Association, Inc. vs. City of Taguig, April 07, 2025)
3. Whether the City of Manila is correct in classifying the corporation as a “holding company” for business tax purposes (CTF Hotel and Entertainment, Inc. vs. City of Manila, CTA EB No. 2987, September 19, 2025)

DOCUMENTARY STAMP TAX

1. This implements the rate adjustments for Documentary Stamp Tax under Sections 174, 176, and 179 of the Tax Code and the amendments to the documents and papers not subject to DST under Sec. 199 of the same code (Revenue Regulations No. 19-2025, August 05, 2025)

BRANCH PROFIT REMITTANCE TAX

1. Whether the company is liable for deficiency Branch Profit Remittance Tax for taxable year 2014 (United International Pictures Aktiebolag vs. CIR, CTA EB No. 2650, April 14, 2025)

STOCK TRANSACTION TAX

1. This implements the rate adjustment of Stock Transaction Tax and its imposition on the sale or exchange of domestic shares of stocks and other securities listed and traded through a foreign exchange under Sec. 127 of the Tax Code (Revenue Regulations No. 20-2025, August 05, 2025)

TAX ASSESSMENTS

1. Whether the Court of Tax Appeals erred in cancelling the BIR’s deficiency tax assessments against the company (Script2010, Inc. vs. CIR, G.R. No. 266641, February 17, 2025)
2. Whether the alleged improper service violated the taxpayer’s right to due process and rendered the assessments void (Fort1 Global City Center, Inc. vs. CIR, G.R. No. 263811, April 2025)
3. Whether the real property tax assessment against the company had become final and unappealable due to its late appeal to the Local Board of Assessment Appeals (Qualfon Phils., Inc. vs. City of Dumaguete, et. al., CTA EB No. 2741, January 15, 2025)

4. Whether the tax assessment is valid given the audit was done by officers not named in the LOA and the FAN/FLD had no definite due date (Concepcion Industries, Inc. vs. CIR, CTA EB No. 2863, January 22, 2025)
5. Whether the deficiency income tax assessment void due to a violation of due process (Spouses Pacquiao vs. CIR, CTA EB No. 2737, January 23, 2025)
6. Whether or not the Court in Division lacks jurisdiction over the Petition for Review (D.M. Wenceslao & Associates, Inc. vs. CIR, CTA EB No. 2802, February 06, 2025)
7. Whether the respondent is estopped from asserting that the LOAs and assessment notices were improperly served (Joselito B. Yap vs. CIR, CTA EB No. 2792, February 11, 2025)
8. Whether the Court of Tax Appeals had jurisdiction to review the case despite the taxpayer’s failure to timely protest the 2015 tax assessment (E-Power Security and Investigation Services, Inc. vs. CIR, CTA EB No. 2747, February 21, 2025)
9. Whether the deficiency tax assessments and warrant of garnishment issued against the company for taxable year 2013 were validly served and enforceable (One Cypress Agri-Solution, Inc. vs. CIR, CTA EB No. 2813, March 05, 2025)
10. Whether the Court of Tax Appeals can review Warrant of Distraint and/or Levy and other BIR collection procedures even if the administrative appeal of tax assessment is still unresolved (AGM Ventures Enterprises, Inc. vs. CIR, CTA EB No. 2829, April 24, 2025)
11. Whether or not the court has jurisdiction over the subject matter of the petition (My Solid Technologies & Devices Corp., CTA No. 10598, May 15, 2025)
12. Whether the deficiency tax assessments issued without a valid Letter of Authority are valid and enforceable against the company (Unick Trend Innovation Corp. vs. CIR, CTA EB No. 2858, May 20, 2025)
13. Whether a proper LOA is necessary in mandatory audit cases (Sellery Phils. Enterprises, Inc. vs. CIR, CTA EB No. 2837, May 20, 2025)
14. Whether the BIR may apply the 10-year prescriptive period by treating the return as “false,” making the assessment valid beyond the 3-year limit (Norkis Trading Co., Inc. vs. CIR, CTA En Banc No. 1766, June 13, 2025)
15. Whether the deficiency tax assessments against the company were valid and enforceable (Will Team PH, Inc. vs. CIR, CTA EB No. 2884, July 16, 2025)
16. Whether the tax assessment against the company was valid despite the absence of a LOA, and whether a Tax Verification Notice can substitute for a LOA (St. Paul Hospital Cavite, Inc. vs. CIR, CTA EB No. 2880, August 15, 2025)
17. Whether the BIR’s 2012 tax assessment and Final Decision on Disputed Assessment against the company were validly issued (Metro Rail Transit Corporation vs. CIR, CTA No. 2862, September 02, 2025)

18. Whether the Petition for Review filed by the company before the CTA was timely and within the court’s jurisdiction (Benguet Electric Cooperative, Inc. vs. CIR, CTA EB No. 2882, September 02, 2025)
19. Whether the company is liable for various taxes collected from planholders (Pet Plans, Inc. vs. CIR, CTA EB No. 2857, September 02, 2025)
20. Whether the CTA had jurisdiction over the dispute concerning the denial of a request to life the notices on tax lien (Boast, Inc. vs. CIR, CTA EB No. 2812, September 16, 2025)
21. Whether the company’s petition for review timely filed under Sec. 112 (C) of the Tax Code, as amended by TRAIN Law (Stefanini Phils., Inc. vs. CIR, CTA EB No. 2849, September 16, 2025)
22. Whether CTA EB has jurisdiction to review the Petition for Review filed by the CIR against the amended decision of CTA Division (Halliburton Worldwide Ltd. – Phil. Branch vs. CIR, CTA EB No. 3070, September 16, 2025)
23. Whether the deficiency tax assessments issued against the company were valid and enforceable (Kepwealth, Inc. vs. CIR, CTA EB No. 3002, September 23, 2025)

ADMINISTRATIVE

1. This implements Secs. 112(C) and 135-A of NIRC, as amended by Sec. 9 and 11 of RA No. 12066 on the Procedures in the Resolution of Requests for Reconsideration on the Denial of Claims for Refund (Revenue Regulations No. 08-2025, February 27, 2025)

2. This implements Secs. 237 and 237-A of NIRC, as amended by RA No. 12066 (Revenue Regulations No. 11-2025, February 27, 2025)
3. This further amends Sec. 5 of RR No. 3-69, relative to due process requirement in the service and execution of summary remedies (Revenue Regulations No. 12-2025, March 06, 2025)
4. This refers to consolidated provisions to simplify the procedures relative to availment of tax exemptions to private entities (Revenue Regulations No. 13-2025, March 31, 2025)
5. This prescribes the revised private retirement benefit plan regulations (Revenue Regulations No. 15-2025, April 29, 2025)
6. This amends pertinent provisions of RR No. 17-2011 to implement Sec. 9 of RA No. 12214, on Additional Deduction of Qualified Employer’s Actual Contributions made to PERA under RA No. 9505 (Revenue Regulations No. 22-2025, August 08, 2025)
7. This suspends the implementation of the requirement to post a bond under Sec. 160 of the NIRC of 1997, as amended, for importers and manufacturers of petroleum products (Revenue Regulations No. 25-2025, October 03, 2025)
8. This amends the transitory provisions of RR No. 11-2025 extending the compliance period for electronic invoice issuance by covered taxpayers (Revenue Regulations No. 26-2025, October 16, 2025)
9. This prescribes the policies, guidelines, and procedures in the processing and issuance of Tax Clearance Certificate for Final Settlement of Government Contracts (TCFG) (Revenue Memorandum Order No. 02-2025, January 06, 2025)
10. This prescribes the policies and guidelines in the reporting of Cannot Be Located (CBL) Taxpayers and procedures in handling the cases pertaining thereto (Revenue Memorandum Order No. 04-2025, January 14, 2025) 

11. This amends the guidelines in the processing of Certificate of Tax Exemption of Non-stock, Non-profit Corporations (Revenue Memorandum Order No. 22-2025, April 29, 2025)
12. This prescribes the guidelines and procedures regarding requests for issuance of a Certified True Copy on Administrative Appeal against FDDA and Denial on Claims for VAT Refund and Excise Tax (Revenue Memorandum Order No. 34-2025, July 07, 2025)
13. This further amends certain provisions of RMO No. 6-2023, as amended by RMO Nos. 8-2023, 1-2024 and 17-2024, concerning the issuance of Tax Clearance Certificate of Liabilities for business closure, etc. (Revenue Memorandum Order No. 36-2025, August 18, 2025)
14. This updates the rules for BIR processing of excise-tax refund claims on petroleum products, aligning them with RR No. 6-2025 and supersedes key parts of RMO No. 16-2024 (Revenue Memorandum Order No. 38- 2025, September 08, 2025)
15. This amends RMO No. 33-2024 on the Modes of Disposition of Seized/ Forfeited Articles (Revenue Memorandum Order No. 41-2025, September 25, 2025)