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Ruby Yusi and Eric Recalde lead the Tax practice at Angara Abello Concepcion Regala & Cruz Law Offices (ACCRALaw), which provides legal advice on both national and local taxation in the banking, real estate, consumer, insurance and energy sectors. The firm recently advised Metropolitan Bank & Trust Co on the client’s intervention in a petition for declaratory relief questioning the regulation issued by the Bureau of Internal Revenue, which limits how banks and other financial institutions allocate expenses between units and income streams. Other key clients include Bank of the Philippine Islands, Banco de Oro Unibank, and SM Prime Holdings.

The Tax practice at Gatmaytan Yap Patacsil Gutierrez & Protacio (C&G Law) advises clients from the power generation, manufacturing, pharmaceutical and mining industries, such as the Aboitiz Group, Holcim Philippines, and OceanaGold. Anthony Gutierrez and Jesus Protacio handle a range of tax matters, including advisory, planning, litigation and corporate restructuring work, and recently advised Sanofi Aventis Philippines Inc. on the tax treatment of its $25m cross-border business unit swap with Boehringer.

Hector Martinez heads the Tax practice at Platon Martinez Flores San Pedro & Leaño, with strong support from Anthony Abenir. The firm continues to act for Chevron, Dole Philippines, and Philippines Sinter Corporation in contesting tax assessments imposed by local government units.

The tax practice at Quiason Makalintal Barot Torres Ibarra Sison & Damaso is led by Wilfrido Sanchez and handles all legal aspects of income, business, estate and transfer taxes imposed by both national and local government. The team specialises in corporate planning, conducting tax audits and preparing tax returns.

The Tax practice group at Quisumbing Torres is headed by Dennis Dimagiba and includes Ronald Bernas, who has expertise in tax planning, audits and compliance, refunds and tax credits, and taxation of financial transactions. The firm advises clients engaged in a range of industry sectors, including construction, consulting, and manufacturing.

Romulo Mabanta Buenaventura Sayoc & De Los Angeles specialises in tax planning and tax litigation, with particular experience in matters involving royalty arrangements, corporate reorganisations, asset dispositions, as well as equity and debt transactions. Priscilla Valer and Jayson Fernandez head the Tax practice.

Ferdinand Hidalgo is the partner to note within Siguion Reyna, Montecillo & Ongsiako’s Tax department, which provides expertise in taxpayer registration issues, tax litigation, and tax refund claims.

Rolando Medalla, Jr heads SyCip Salazar Hernandez & Gatmaitan’s tax practice, which handles the full range of tax services. The firm specialises in tax compliance, planning, ruling requests, refund claims and tax litigation matters, and advises clients engaged across a wide range of industry sectors. Recent work examples include acting on behalf of Lear Automotive Services in the successful litigation of a case involving deductible royalties for purposes of determining the gross income tax base subject to the special 5% tax on enterprises located in export processing zones.

The Tax group at Villaraza & Angangco (V&A Law) is led by Sylvette Tankiang, who is strongly supported by Franchette Acosta. It advises on contentious and non-contentious matters, acting for a wide range of clients such as Rizal Commercial Banking Corporation, Austral-Asia Link Mining Corporation, and Korea East-West Power Corporation. The firm assisted BayWa R.E. Solar with the handling of the corporate and tax structuring its proposed investment in a solar energy project in the Philippines at an estimated project cost of $30m.

Jorge Melo at Zambrano Gruba Caganda & Advincula represented Philippine Airlines in a $5.1m claim for refund of specific taxes paid for importations of Jet A-1 aviation fuel for its domestic flight operations. Other notable clients include the Philippine National Bank and Air Philippines Corporation.

Tax boutique Baniqued & Baniqued provides services in the full range of tax matters, with particular expertise in providing counsel to clients on strategic planning, major cross-border business transactions, tax investigations, and litigation proceedings. Key clients include San Miguel Corporation, UBS Financial Services, and British American Tobacco.

Castillo Laman Tan Pantaleon & San Jose’s Tax practice is active in the planning and advocacy side, with experience in advising clients on tax compliance, tax rulings, and internal revenue audits. Ma Victoria Sarmiento and Joseph Castillo are the key Tax partners.

Carlos Ocampo and Manolito Manalo at Ocampo Manalo Valdez & Lim advise clients on corporate taxation structures, compliance issues, and estate planning.

Ortega Bacorro Odulio Calma & Carbonell’s practice handles statutory, regulatory, constitutional and common-law tax matters. Name partners Gregorio Ortega and Renato Calma are key contacts.

The Tax group at Picazo Buyco Tan Fider & Santos has experience in all areas of tax planning and counselling, with particular expertise in estate planning and litigation. Antonio Picazo is the key contact at the firm.

Poblador Bautista & Reyes advises clients on tax avoidance measures and securing tax clearances, as well as providing expertise in tax matters relating to property and estates. Raymund Rodriguez is particularly active in this area.

The practice at Puyat Jacinto & Santos Law Offices has extensive experience in tax consultancy and structuring for local and foreign investments, and provides advice on tax assessments, litigation and appeals to domestic and international clients. Pearl Cabali and Virginia Viray are the partners to note.

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Legal Developments in Philippines

Legal Developments and updates from the leading lawyers in each jurisdiction. To contribute, send an email request to
  • SyCipLaw TMT Bulletin: “More Philippine Data Privacy Act: Are you Ready for Phase II?”

    Controllers and processors who have completed Phase I registration with the National Privacy Commission (NPC) will now have to gear up for Phase II. Phase II involves providing the NPC certain information on the organization’s compliance with the Data Privacy Act (DPA).
  • Getting the Deal Through: Appeals 2017

    The Philippine chapter of Getting the Deal Through: Appeals 2017 was contributed by SyCipLaw partner Ramon G. Songco and associate Kathleen Kay A. de Guzman . The chapter provides key insight into the appellate stage of dispute resolution in the Philippines.
  • The International Comparative Legal Guide to: Patents 2018

    The Philippine chapter of the International Comparative Legal Guide to: Patents 2018 was contributed by SyCipLaw partners Enrique T. Manuel and Vida M. Panganiban-Alindogan . The chapter answers key questions on patent enforcement, patent amendment, licensing, patent term extension, patent prosecution and opposition, border control measures, and antitrust laws and inequitable conduct. It also gives an overview on current patent developments in the country.
  • IBA Taxes Committee: “Developments in Philippine Tax Laws and Regulations”

    The International Bar Association’s (IBA) Taxes Committee published its annual update on tax developments by jurisdiction for 2017. The 2017 update includes a Philippine report by SyCipLaw partner Hiyasmin H. Lapitan entitled “Developments in Philippine Tax Laws and Regulations”. The Philippine report summarizes recent updates related to tax treaty relief, passed-on gross receipts tax, alternative modes of paying taxes, reduction of real property tax on independent power producers, and case law, as well as upcoming tax reform developments.
  • ALB: “Enforcement Update: Philippine Competition Act”

    The August 2017 issue of the Asian Legal Business (ALB)  includes a Philippine regional update by SyCipLaw partner  Arlene M. Maneja entitled, “Enforcement Update: Philippine Competition Act”. The article summarizes the administrative, civil and criminal penalties that apply to companies that have yet to comply with the Philippine Competition Act (PCA). The transitional clause of the PCA to enable parties to renegotiate agreements or restructure their businesses to comply with the law expired on August 7, 2017.
  • CPO: “Philippines: To Be or Not To Be a Data Protection Officer (DPO)”

    Chief Privacy Officer (CPO) Magazine, an online publication owned by Data Privacy Asia, featured an article by SyCipLaw partner Rose Marie M. King-Dominguez . Entitled “Philippines: To Be or Not To Be a Data Protection Officer (DPO) ”, the article discusses the qualifications and responsibilities of a DPO as outlined in the Philippine Data Privacy Act of 2012. It also outlines difficulties companies may experience in the appointment of a DPO.
  • ALB: “Guidelines on Related Party Transactions for Insurers in the Philippines”

    The July 2017 issue of the Asian Legal Business (ALB) includes a Philippine regional update by SyCipLaw partner Hiyasmin H. Lapitan and associate Jo Margarette W. Remollo entitled, “Guidelines on Related Party Transactions for Insurers in the Philippines ”. The article summarizes the Insurance Commission’s compliance guidelines on related party transactions, as set out in Insurance Circular Letter No. 2017-29. The Circular covers insurers, reinsurers, branch offices of foreign insurers, mutual benefit associations, pre-need companies, and health maintenance organizations and their intermediaries.
  • Philippines Chapter in The Tax Disputes and Litigation Review - Edition 5

    The Philippines section of The Tax Disputes and Litigation Review - Edition 5 contains information on commencing disputes, including national and local taxes; courts and tribunals; penalties and remedies; tax claims, including recovering overpaid taxes, challenging administrative decisions, and claimants; costs; alternative dispute resolution; anti-avoidance; double taxation treaties; areas of focus; and outlook and conclusions. The section was contributed by SyCipLaw partner  Carina C. Laforteza  with support from associate  Mark Xavier D. Oyales .
  • IFLR: “Philippines: Acquiring insurance brokers”

    The April issue of the International Financial Law Review (IFLR) includes an international briefing article by SyCipLaw partner  Hiyasmin H. Lapitan  entitled “Philippines: Acquiring insurance brokers”. The article discusses the new requirement by the Philippine Insurance Commission (IC) for advance approval to acquire a stake in a Philippine corporation that is licensed as an insurance broker or reinsurance broker. This requirement is noted in the IC’s circular letter number 2017-09 dated February 14, 2017, which prescribes guidelines on the documentation requirements for acquiring a domestic insurance or reinsurance broker.
  • SyCipLaw Tax Bulletin: Philippine BIR Rules on Proper Tax Treatment of Passed-on Gross Receipts Tax

    On June 13, 2016, the then Commissioner of Internal Revenue issued Revenue Memorandum Circular No. 62-2016 purporting to clarify the proper tax treatment of percentage tax or gross receipts tax (GRT) due on transactions covered by Sections 1211 and 1222 of the Tax Code which are shifted through contractual stipulations to borrowers/customers/clients (“passed-on” GRT). Banks, non-bank financial intermediaries performing quasi-banking functions are subject to GRT under Section 121 while financing companies and other financial intermediaries not performing quasi-banking functions are subject to GRT under Section 122. The effectivity of this circular was suspended on July 1, 2016 by the new Commissioner of Internal Revenue. However, on November 15, 2016, the suspension was lifted by RMC No. 127-2016 rendering RMC No. 62-2016 effective immediately.

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