Subject: WEEKLY TAX UPDATES [SEPT 30] PH nets nearly P3-B digital VAT from tech companies

WEEKLY TAX UPDATES

SEPTEMBER 30

  1. TAX & BUSINESS-RELATED NEWS [SEPTEMBER 23-29]

  2. BIR FURTHER AMENDS THE RULES ON THE IMPOSITION OF CREDITABLE WITHHOLDING TAX ON TOP WITHHOLDING AGENTS

  3. CTA CASES

1. TAX & BUSINESS-RELATED NEWS [SEPTEMBER 23-29]

1. PH nets nearly P3-B digital VAT from tech companies

2. PHL urged to sign double taxation agreement with Ireland

3. IFC mulls $10-M bet on Philippine retailer Dali

4. APECO seeking investors for P4.7 billion seaport

5. Eton City named Sta. Rosa’s top real property taxpayer

6. MBC calls for AI-based corruption fighting tools

7. BIR needs to be mobilized in anti-corruption effort — ACG

8. Construction goes high-tech

9. Supreme Court orders bank to pay depositors for negligence, awards moral damages

10. ALI rolling out P4.4 billion commercial lots in Tarlac

11. Property prices soar outside Metro Manila despite nationwide slowdown

12. Insurance company offers plan for pets, proceeds go to animal welfare efforts

13. DPWH exec in Western Visayas sued over demolition of ‘historic’ bridge

14. Shipping association seeks investigation of Marina officials

15. BoI hopes to release updated SIPP before yearend

16. D&L units get additional two-year tax holiday from PEZA

17. BSP’s P500,000 cash withdrawal limit ‘not foolproof’ — analysts

18. Ayala Land: New World Hotel price tag is ₱1.43B

19. New tax law spurs ‘dramatic’ retreat from long-term bank savings

20. Ex-DOF chief: Make P200 largest bill to curb corruption

21. Megaworld touts flooding solution in Pampanga township

22. Mayor encourages drugstores to accredit with PhilHealth

23. Landlords urged to improve offices, offer concessions in tenant-leaning market

24. SEC backs changes to bank secrecy law

25. Philippines found most dishonest in region on money matters

26. Legislator says Finance department open to discussing tax on billionaires

27. Makro reentering Philippine market, backed by Ayala

28. Visa prepares Philippine banks to adopt Apple Pay, Google Pay, and Samsung Pay

29. Price isn’t everything for Filipino online shoppers, study says

30. United Architects of the Philippines condemns the use of 'architect' in reports about plunder, corruption

DISCLAIMER!

We saw these tax and business-related news on various news sites, and we thought you should see them. DMD is not responsible for the content of these news, and anything written thereon does not necessarily reflect DMD views or opinions.

PH nets nearly P3-B digital VAT from tech companies [Philippine Daily Inquirer, September 29, 2025]

Of that amount, P1.65 billion was paid for business-to-customer transactions. Total collections for business-to-business deals reached P1.14 billion.

 

PHL urged to sign double taxation agreement with Ireland [BusinessWorld, September 29, 2025]

The Philippines has around 44 double taxation agreements, including those with the US, the UK, Spain, South Korea, Japan, Germany, China, Canada, and Australia.

 

IFC mulls $10-M bet on Philippine retailer Dali [Philippine Daily Inquirer, September 29, 2025]

The International Finance Corp. is considering a $10 million investment in Dali Everyday Grocery, a rapidly expanding hard-discount retailer in the Philippines.

 

APECO seeking investors for P4.7 billion seaport [The Philippine Star, September 29, 2025]

The Aurora Pacific Economic Zone and Freeport Authority (APECO) is looking for firms interested in the development of a P4.7 billion seaport in the ecozone.


Eton City named Sta. Rosa’s top real property taxpayer [The Philippine Star, September 29, 2025]

Subsidiaries of Lucio Tan-owned Eton Properties Philippines Inc. were recognized among Sta. Rosa’s top real property taxpayers at the 2025 Lion Awards for Business, the city’s annual recognition program for companies that contribute significantly to local development.

 

MBC calls for AI-based corruption fighting tools [BusinessWorld, September 29, 2025]

“They are under a lot of pressure to produce instant results. They (need to) work with the low-hanging fruit, which is essentially all of the cases already investigated by the Congress,” MBC Executive Director Rafael ASG Ongpin told reporters on the sidelines of the Arangkada Forum last week.


BIR needs to be mobilized in anti-corruption effort — ACG [BusinessWorld, September 28, 2025]

“People are angry; are already clamoring not to pay taxes, so civil disobedience (could be emerging). We do not support that; we want taxes to still be paid,” ACG Chief Tax Advisor Raymond Abrea told BusinessWorld on the sidelines of the Arangkada Forum.

 

Construction goes high-tech [Philippine Daily Inquirer, September 28, 2025]

First Balfour Inc., the Lopez Group’s construction and engineering arm, has adopted an artificial intelligence (AI)-powered construction management system (CMS) that integrates into a single platform the planning, execution and monitoring of projects for faster and more efficient management.

 

Supreme Court orders bank to pay depositors for negligence, awards moral damages [The Manila Times, September 27, 2025]

BANKS are liable for moral damages due to negligence alone, even in the absence of bad faith or malice, according to a Supreme Court ruling made public on Thursday.

 

ALI rolling out P4.4 billion commercial lots in Tarlac [The Philippine Star, September 27, 2025]

Property giant Ayala Land Inc. (ALI) is preparing inventory worth P4.4 billion for the third phase of commercial lot rollout at its 290-hectare Cresendo estate in Tarlac.

 

Property prices soar outside Metro Manila despite nationwide slowdown [The Manila Times, September 27, 2025]

The median price for all types of houses was P3.406 million in the second quarter, the BSP said, with condominium units higher at P3.807 million and houses at P3.138 million.

 

Insurance company offers plan for pets, proceeds go to animal welfare efforts [The Philippine Star, September 27, 2025]

FWD Life Insurance Corp. launched a new plan for pets and their owners, where proceeds help fund programs of local animal welfare group the Philippine Animal Welfare Society (PAWS).

 

DPWH exec in Western Visayas sued over demolition of ‘historic’ bridge [Inquirer Visayas, September 27, 2025]

Originally constructed by the United States Steel Products Company, the bridge played a key role in the logistics of the sugar industry during the American colonial period, he added.

 

Shipping association seeks investigation of Marina officials [Inquirer.Net, September 26, 2025]

The Philippine Interisland Shipping Association (Pisa) has asked the Office of the Ombudsman to conduct a fact-finding investigation of some officials of the Maritime Industry Authority (Marina) for purportedly allowing land craft tank (LCT) barges — considered cargo vessels — to carry passengers.

 

BoI hopes to release updated SIPP before yearend [BusinessWorld, September 26, 2025]

The Board of Investments (BoI) said that the government is already fine-tuning the details of the updated Strategic Investment Priority Plan (SIPP) 2025-2028, with hopes of releasing within the year the updated list of projects that will qualify for incentives.

 

D&L units get additional two-year tax holiday from PEZA [GMA News Online, September 26, 2025]

Subsidiaries of chemicals and food ingredients maker D&L Industries, D&L Premium Foods Corp. (DLPF) and Natura Aeropack Corp (NAC), have secured "pioneer status" from the Philippine Economic Zone Authority (PEZA), granting the firms additional two years of Income Tax Holiday (ITH). 

 

BSP’s P500,000 cash withdrawal limit ‘not foolproof’ — analysts [BusinessWorld, September 26, 2025]

“Loopholes such as ‘smurfing’ (structuring under-threshold withdrawals) and shifts to informal or offshore methods must be monitored,” Mr. Rivera added. “Banks should strengthen transaction monitoring and customer profiling, while regulators must remain vigilant.”

 

Ayala Land: New World Hotel price tag is ₱1.43B [BusinessMirror, September 26, 2025]

Property developer Ayala Land Inc. has purchased New World Hotel Makati, a landmark property in the country’s financial and commercial hub, for about P1.43 billion.

 

New tax law spurs ‘dramatic’ retreat from long-term bank savings [Philippine Daily Inquirer, September 25, 2025]

The new law ending tax breaks on long-term time deposits has triggered a “dramatic” exodus from those savings products, leaving banks and policymakers to wonder where the cash will flow next.

 

Ex-DOF chief: Make P200 largest bill to curb corruption [The Philippine Star, September 25, 2025]

Demonetizing P1,000 and P500 bills will make it harder for corrupt officials to conceal and transport illicit funds, former finance chief Cesar Purisima said yesterday.

 

Megaworld touts flooding solution in Pampanga township [The Philippine Star, September 25, 2025]

In a video posted on his social media page, Tan, president and CEO of conglomerate Alliance Global Group Inc., bared plans to bring Megaworld’s Rainwater Park model to more townships nationwide to help in solving flooding problems.

 

Mayor encourages drugstores to accredit with PhilHealth [The Manila Times, September 25, 2025]

Under the program, every PhilHealth member can avail themselves of free medicines of up to P20,000 from all PhilHealth-accredited pharmacies. Because of this, Mayor Ermita-Abad encourages local pharmacies and drugstores to get accredited with PhilHealth.

 

Landlords urged to improve offices, offer concessions in tenant-leaning market [BusinessWorld, September 25, 2025]

In its Survey Flash Report released on Wednesday, Colliers said six out of 10 respondents are now working in a traditional office setup, slightly higher than the 54% recorded in the fourth quarter of 2024.

 

SEC backs changes to bank secrecy law [The Manila Times, September 25, 2025]

Several measures are pending before the House of Representatives seeking to lift or relax the bank secrecy law, primarily to promote transparency and curb corruption in government.

 

Philippines found most dishonest in region on money matters [Philippine Daily Inquirer, September 24, 2025]

ROSHI, a Singapore-based fintech firm, said in its Financial Honesty Study: Southeast Asia report that the Philippines had the highest financial misreporting rate in the region at 47 percent, which means that about half are not likely to give an accurate picture of their financial situation.

 

Legislator says Finance department open to discussing tax on billionaires [BusinessWorld, September 24, 2025]

Sultan Kudarat Rep. Bella Vanessa B. Suansing, speaking at the hearing late Wednesday with Finance Secretary Ralph G. Recto seated near her, said: “The DoF is very open to discussions relating to the wealth tax to be integrated into the revenue program of the National Government,” she said at the hearing.

 

Makro reentering Philippine market, backed by Ayala [Philippine Daily Inquirer, September 24, 2025]

MROH is a a subsidiary of CP Axtra Public Company Limited, a wholesale and retail business operator and mall management firm in Thailand and overseas markets. It is part of the Charoen Pokphand Group.

 

Visa prepares Philippine banks to adopt Apple Pay, Google Pay, and Samsung Pay [Technobaboy, September 24, 2025]

The Bangko Sentral ng Pilipinas (BSP) recently clarified that these wallets are technology service providers. They must be linked to users’ credit, debit, or e-money accounts. They cannot hold funds directly. This puts banks in charge of enabling access to these services.

 

Price isn’t everything for Filipino online shoppers, study says [Philippine Daily Inquirer, September 24, 2025]

A study by global market research and data analytics firm Milieu Insight showed that 55 percent of Filipino shoppers would buy more from sellers who “communicate responsively and give timely updates.”

 

United Architects of the Philippines condemns the use of 'architect' in reports about plunder, corruption [The Philippine Star, September 23, 2025]

In its statement on Tuesday, Sept. 23, the UAP called out headlines and news articles that use the word "architect" when referring to a government official linked to plunder, saying the misuse tends to equate their profession with orchestrators of wrongdoing.

2. BIR FURTHER AMENDS THE RULES ON THE IMPOSITION OF CREDITABLE WITHHOLDING TAX ON TOP WITHHOLDING AGENTS

Revenue Regulations (RR) No. 24-2025, issued on September 25, 2025, further amends Section 2.57.2.(I) of RR No. 2-98, as amended by RR No. 11-2018, on the imposition of Creditable Withholding Tax (CWT) by Top Withholding Agents (TWAs). Specifically, a 1/2% CWT shall be imposed on gross payments to manufacturers and direct importers of goods intended for wholesale, in lieu of the usual 1%/2%, as follows:”

 

1. Motor vehicles in Completely Built Units (CBUs) or Semi-Knockdown (SKD) units, motor vehicle parts, and accessories

2. Medicine/pharmaceutical products

3. Solid or liquid fuels and related products

3. CTA CASES

[A TAXPAYER MAY APPEAL THE CIR’S DECISION ON A REFUND CLAIM WITHIN 30 DAYS FROM RECEIPT OF THE DECISION, EVEN IF IT WAS ISSUED BEYOND THE PRESCRIPTIVE 90-DAY PERIOD] [JURISPRUDENCE APPLYING THE “WHICHEVER IS SOONER” RULE UNDER THE 90+30 DAY PERIOD NO LONGER APPLIES, AS THE AMENDED LAW NOW PROVIDES A CLEAR & SPECIFIC REMEDY]

Petitioner Stefanini Philippines Inc. filed a Petition for Review praying for the reversal of the Resolutions specifically for the instant case to be remanded to the Court in Division for the continuation of the proceedings. The Petitioner argues that the Court has jurisdiction since the Petition for Review was filed within the thirty (30) day period under Section 112(C) of the Tax Code, as amended by Republic Act (RA) No. 10963, also known as the Tax Reform for Acceleration and Inclusion or TRAIN (2018) Law. It points out that references to inaction were removed, and even the BIR expressly advised that an appeal may be made within 30 days from receipt of its VAT Refund Notice. Petitioner also contends that the strict application of the ninety plus thirty (90+30) rule will only cause procedural inefficiencies and unnecessary cases, emphasizing that the BIR is not precluded from granting a refund even after the 90-day period. Lastly, Petitioner maintains that the delay in the service of the Commissioner of Internal Revenue’s (CIR) decision, which was beyond its control, caused the lapse of the 90+30 period. Thus, it should not be deprived of its legal remedy due to circumstances not of its own making. On the other hand, the respondent CIR argues that the Court in Division has no jurisdiction over the Petition since Section 112(C) of the Tax Code, when read with Section 7(a)(1) of RA 1125, as amended by RA 9282 or CTA Law, requires that a judicial claim be filed within 30 days from either receipt of the CIR’s decision or the expiration of the 90-day period, whichever comes first. The Respondent contends that the CIR’s inaction is, by express provision of law, a “deemed denial,” and failure to appeal within 30 days from such deemed denial renders the case final and unappealable. In ruling, the Court held that the Petition for Review was timely filed and that the CTA in Division erred in dismissing the case for lack of jurisdiction. The court explained that under Section 112(C) of the Tax Code, as amended by the TRAIN Law, the taxpayer may appeal the CIR’s decision on a refund claim within 30 days from receipt of the decision, even if such a decision was issued beyond the 90-day period. The Court emphasized that the TRAIN Law deliberately deleted references to appeals from inaction, showing legislative intent to allow appeals only from the CIR’s decision. It further clarified that prior to the TRAIN law, jurisprudence applied the “whichever is sooner” rule under the 90+30 framework, this no longer governs since the amended law provides an unambiguous remedy. Therefore, the Petitioner’s judicial claim was properly filed within the 30-day period from receipt of the CIR’s decision, and the Division’s dismissal was erroneous. Thus, the Petition is GRANTED, and the Resolution are REVERSED and SET ASIDE. [STEFANINI PHILIPPINES INC. VS. COMMISSIONER OF INTERNAL REVENUE, CTA EB NO. 2849, SEPTEMBER 11, 2025]


WHEN IT APPEARS FROM THE PLEADINGS OR THE EVIDENCE ON RECORD THAT THE COURT HAS NO JURISDICTION OVER THE SUBJECT MATTER, THE COURT SHALL DISMISS THE CLAIM

Petitioner Benguet Electric Cooperative, Inc. (BENECO), filed a Petition for Review seeking the reversal of the Court's Special Second Division’s (Court in Division) Decision and Resolution, dismissing its original Petition for lack of jurisdiction, and praying for the rendition of a decision based on the merits of the case. The Petitioner argued that since the issue of jurisdiction was never raised in the case before the Court in Division, the Respondent Commissioner of Internal Revenue (CIR) is deemed to have waived its right to question the same. It emphasized that the Respondent actively participated in all stages of the Court of Tax Appeal (CTA) proceedings and had ample opportunity to question the timeliness of the Petition, but did not do so. Therefore, the issue of jurisdiction should no longer be considered. The Petitioner also maintained that the Petition was filed within the prescribed period. On the other hand, the Respondent countered that jurisdiction over the subject matter or nature of action is conferred by law and not by  consent or waiver before the court. In ruling, Section 1, Rule 14 of the Revised Rules of the Court of Tax Appeals (RRCTA) expressly authorizes the CTA to rule on issues beyond those stipulated by the parties if the same would be necessary to achieve the orderly disposition of a case. The CTA, being a court of special jurisdiction, may only hear cases clearly within its authority. A determination of the existence of jurisdiction over the subject matter is essential, as it affects the validity of all proceedings. Citing the Supreme Court (SC) case of Nippon Express (Philippines) Corporation vs. CIR, the Court categorically instructed the CTA to dismiss a case upon determination of lack of jurisdiction after review of the pleadings and the evidence on record. Moreover, specific to the issue of prescription similar to the case at hand, the Court cited the SC ruling in China Banking Corporation v. CIR, which held that if the evidence on record show that the claim is barred by prescription, even if prescription is not raised as a defense, then there is nothing for the court to do but dismiss the case outright. In the case at bar, while it is true that the Respondent never raised the issue of jurisdiction, it also did not question the Court in Division's jurisdiction after obtaining an unfavorable judgment. The Court held that Petitioner's claim of estoppel was misplaced and concluded that the original Petition, filed on October 30, 2018, was untimely, thereby depriving the Court in Division of jurisdiction over the case. In view of this, the Petition was DENIED for lack of merit, and the Decision, dated September 11, 2023, and the Resolution, dated January 24, 2024, of the Court in Division were AFFIRMED. [BENGUET ELECTRIC COOPERATIVE, INC. (BENECO) VS. COMMISSIONER OF INTERNAL REVENUE, CTA EN BANC CASE NO. 2882, SEPTEMBER 2, 2025]


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