Client Advisory Letter (April 2007)

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Not the time for spa
“The spring cannot rise above its source.” This is one phrase that captures one of the most basic principles which should underlie administrative issuances, i.e., common sense.

BIR

Revenue Memorandum Circular (RMC)

  • Publishing RA No. 9400 (amending the BCDA Law)
  • Publishing RA No. 9399 (One-Time Amnesty Law)
  • New paradigm in meeting collection target
Revenue Memorandum Order (RMO)
  • Guidelines and Procedures on the Use of Revenue Official Receipts (RORs) during specified tax deadlines in areas where there are AABs
  • Verification of Tax Returns by Revenue District Offices
Delegated Authority - International Tax Affairs Division (DA-ITAD) Rulings
  • Payments for purchased trademarks not considered as royalties
  • Income of a foreign corporation derived from sources outside the Philippines is exempt from Philippine income and value-added taxes
  • Payments for loan guarantees not classified as business profits
  • Tax on sale of listed shares not covered by RP-Singapore tax treaty
  • Tax treatment of profits under the RP-Singapore/Korea Tax Treaties
  • Treatment of dividends paid by a domestic company to a corporate shareholder residing in Australia
  • Software payments for transfer of copyright rights are royalties
VAT Review Committee Ruling
  • PCNC's fees are subject to VAT

Supreme Court (SC)
  • Negotiability not a prerequisite for a taxable certificate of deposit

Court of Tax Appeals (CTA)
  • Claim for refund of input VAT on capital goods should be properly documented
  • Certificate of inward remittance does not substantiate VAT zero-rated export sales
  • Absence of BIR's Authority to Print (ATP) on sales invoice bars tax refund/credit claim

Republic Acts (RA)
  • An Act Amending Republic Act (RA) No. 7227 otherwise known as The Bases Conversion and Development Act (BCDA) of 1992
  • An Act Declaring a One-Time Tax Amnesty for Clark, John Hay, Morong and Poro Point SEZs

Bangko Sentral ng Pilipinas (BSP)
  • Valid identifications (ID) cards

Philippine Economic Zone Authority (PEZA)
  • Attachment of PEZA Certificate of Incentives to ITR

Insurance Commission
  • Accredited External Auditors

"Meet Us"
  • Tax Consulting
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Contacts
Mary Assumption Bautista-Villareal
Principal, Tax
Tel: +63 (2) 845 2728
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