Philippines Court of Tax Appeals Issues Decision Clarifying Validity of Assessments for Alleged Tax Deficiencies

The Philippine Court of Tax Appeals Nov. 21 issued a decision in CTA Case No. 11084, clarifying the validity of assessments for alleged tax deficiencies. The taxpayer, a corporation, challenged deficiency assessments for income tax (IT) and VAT. The Commissioner of Internal Revenue argued that the assessments were valid and enforceable. On appeal, the Court of Tax Appeals, First Division, found that: 1) the preliminary assessment notice (PAN) and formal letter of demand (FLD) with final assessment notice (FAN) weren’t properly served and received when there was no effort to determine the taxpayer’s new location and no authenticated signature, violating ...