Tax in Philippines

Angara Abello Concepcion Regala & Cruz Law Offices (ACCRALaw)

Angara Abello Concepcion Regala & Cruz Law Offices (ACCRALaw)‘s tax department enjoys a stellar reputation in the domestic market for its track record in administrative and judicial cases, most notably in handling the issuances of both local and national tax authorities. The team places an emphasis on representing various banks and professional associations in challenging issuances of the Bureau of Internal Revenue before the courts. Headed up by Ruby Rose J Yusi, Eric R Recalde and Oliver L Pantaleon, the group also advises local conglomerates, multinationals, listed companies and high net-worth individuals on tax advisory and planning issues, running the full gamut of national, local, and customs taxes and duties. Advising on the tax implications of corporate transactions is another mainstay of the group.

Key clients

Banco De Oro Unibank, Inc.

Bangko Sentral ng Pilipinas

Citibank N.A.

Metropolitan Bank & Trust Company

Philippine National Bank

Sumitomo Mitsui Banking Corporation

Union Bank of the Philippines

Allegro Microsystems Philippines, Inc.

Araneta Group of Companies

Beiersdorf Philippines, Inc.

Campaigns and Grey, Inc.

Del Monte Phillipines, Inc.

Hershey Philippines, Inc.

Light Rail Manila Corporation

Procter & Gamble Philippines, Inc.

Rappler, Inc.

Smartmatic Philippines

SM Prime Holdings, Inc.

Subic Water and Sewerage Co., Inc.

Sumisetsu Philippines, Inc.

Tetra Pak (Philippines), Inc.

Mitsubishi Motors Philippines Corporation

HC Consumer Finance Phils. Inc.

Gatmaytan Yap Patacsil Gutierrez & Protacio (C&G Law)

Led by Anthony Gutierrez, the team at Gatmaytan Yap Patacsil Gutierrez & Protacio (C&G Law) acts both for domestic conglomerates and multinationals, drawn from an array of sectors, in disputing tax assessments related to internal revenue taxes before state authorities, administrative tribunals, the Court of Tax Appeals and the Supreme Court. Additionally, the group specialises in tax compliance issues as well as the implementation of complex tax structures in high-value M&A, large-scale infrastructure projects and energy mandates. Another name to note is Roxanne Tadique, who also displays capabilities in tax incentive, tax treaty relief and audit investigation matters.

Other key lawyers:

Roxanne Tadique; Sophia Inoturan

Key clients

FGEN LNG Corporation

Aboitiz Group of Companies

SM Prime Holdings, Inc.

Robinsons Land Corporation

Ayala Group of Companies

TeaM Energy Corporation

CE Casecnan Water and Energy Company, Inc.

Webb Fontaine Group

Metro Rail Transit Corporation (MRTC)

Charoen Pokphand Foods Philippines Corporation

Work highlights

  • Advising FGEN LNG Corporation power generation group on a $1bn LNG infrastructure development project with onshore and offshore components.
  • Represented and obtained a favourable judgement for East Asia Utilities Corp in a tax case before the Supreme Court.
  • Advised a wholly-owned subsidiary of Aboitiz group on real property taxes assessed against its powerplant’s pollution control equipment, including the first coal dome built in the country, with a cost of around $20m to build, and with real property tax due thereon amounting to around $9m from 2016 to date.

Quisumbing Torres

Integrated into the global Baker Mckenzie network, Quisumbing Torres‘ practice has considerable experience in general tax planning, tax litigation and customs issues and procedures. More specifically, the department, which is overseen by the ‘very experiencedRonald Bernas, frequently advises on the tax dimensions of corporate reorganisations and real estate transactions, income and withholding tax issues, international trade and customs matters, tax and customs audits, tax incentives, as well as trusts and wealth management issues. Kristine Anne Mercado-Tamayo, who routinely conducts advocacy in disputed assessments before the Bureau of Internal Revenue and the Bureau of Customs, is an additional key member of the group, which lost Dennis Dimagiba to retirement in December 2020.

Practice head(s):

Ronald Bernas

Testimonials

The team assigned to us is very proactive and has a very deep knowledge of our business and industry. They take the time to let us know of developments that may affect us and as such we then get the time needed to make informed decisions.’

Ronald Bernas is very experienced in this field and he and his team were able to assist us during the time of COVID in a timely manner and they have been very persistent in efforts to ensure that the deliverables are accomplished in a timely manner even during difficult period we are in.’

Key clients

Alphabet (Google Inc.)

Grab Financial Services Philippines, Inc.

Grab Taxi Holdings Pte Ltd.

Graymont Limited

Work highlights

  • Advised an American multinational consulting firm on the most tax-efficient manner of distributing the retained earnings of its Philippines entity to its foreign shareholders.
  • Advised a multinational investment bank and financial services firm on the proposed restructuring of an existing wealth planning structure established by a high-net-worth individual resident of the Philippines.
  • Advised a trade group on the tax implications of the drafts of the Digital Economy bill currently pending with Philippine legislature and advocated, on behalf of the group, and proposed changes to the draft bill for consideration of certain legislators.

SyCip Salazar Hernandez & Gatmaitan

SyCip Salazar Hernandez & Gatmaitan provides the full spectrum of tax services for clients, which range from major corporations to high-net-worth individuals and estates. Tax department lead Carina Laforteza, managing partner Hector de Leon, customs expert Russel Rodriguez and tax litigator Ronald Mark Lleno count amount the headline names, advising on everything from the tax aspects of corporate transactions to administrative and judicial litigation, in which clients are defended against assessments for national, local taxes and customs duties. Also providing key support in this area is Maria Christian Ortuan-Ang, who was promoted to partner in January 2021. Rolando V. Medalla, Jr. is now of counsel and remains a vastly experienced figure across tax issues.

Other key lawyers:

Hiyasmin Lapitan; Maria Christian Ortuan-Ang; Rolando V. Medalla, Jr

Testimonials

‘They have the legal expertise that we seek. They are thorough, and promptly provide advice.’

‘They are friendly and approachable. This is as important as their legal expertise.’

As a client, we are not after uniqueness but we want advice that will keep us away from trouble; there should be less friction cost and must be efficient and doable. They do this excellently.’

They are very competent in their field of expertise and will find ways to help in the fulfillment of the transaction. They are very honest in disclosing the limitations/consequences of the advice given.’

Villaraza & Angangco (V&A Law)

At Villaraza & Angangco (V&A Law), the tax team advises an assortment of multinationals, domestic corporations and high-net-worth individuals on sophisticated tax matters. In addition to its tax expertise in major transactions such as M&A, corporate restructurings and energy and infrastructure projects, the group also has extensive experience in tax investigations and litigation before the Bureau of Internal Revenue, the Department of Justice and the Court of Tax Appeals, among other venues. Raoul Angangco, Sylvette Tankiang and Franchette Acosta are the standout names. In recent news, Kristin Charisse Siao  left the department in 2020.

Testimonials

‘V&A has provided an excellent service to our company. The tax opinions and advice were very comprehensive. The details provided and references were very useful for our decision-making. The team was able to accommodate our requests without delay despite the pandemic restrictions.’

‘The immediate acknowledgement email to our inquiry (and useful reference links on an opinion) were very much appreciated. The content of their reports are also very helpful in our decision making.’

Key clients

China Telecommunications Corporation

Emperador Distillers, Inc.

EWP Philippines, Inc.

Abundance Providers and Entrepreneurs Corporation

InfinitusHealth Products (Philippines) Inc.

UC38, LLC.

Sinokor Merchant Marine Co. Ltd.

Nissan Philippines, Inc.

PricewaterhouseCoopers Korea

Work highlights

  • Advised China Telecommunications Corporation on its investment in DITO Telecommunity Corporation, including the tax consequences of the client’s and DITO’s structuring of the entire transaction, investment schemes and financing of the joint venture.
  • Advised Udenna Corporation on its acquisition of all of the issued share capital of UC38, LLC.
  • Advised Lotte Chilsung Beverage Co. Ltd on tax efficient structures of its corporate restructuring.

Zambrano Gruba Caganda & Advincula

A member of the WPG Law Network, Zambrano Gruba Caganda & Advincula is particularly adept at disputing Bureau of Internal Revenue assessments, often appearing before the Supreme Court and the Court of Tax Appeals in high-value matters. On top of this longstanding strength, Lily Gruba  is noted for her wide-ranging expertise in tax planning and deficiency tax assessments; Angelo Patrick Advincula  specialises in assisting MNCs; Jorge Alfonso Melo  regularly represents Philippines Airlines in major tax issues; Juan Miguel Victor De La Fuente  is well-versed in the tax audit process and tax compliance; while Antero Jose Caganda  handles a broad spectrum of tax issues.

Key clients

Philippine Airlines, Inc.

G & W Architects, Engineers and Project Consultants, Co.

Island Quarry and Aggregates Corporation

Asia United Leasing and Finance Corporation

Work highlights

  • Represented Philippine Airlines, Inc. before the Supreme Court in a dispute of assessments for excise taxes on importations of aviation fuel used by the client for its domestic airline operations, securing favourable decisions.
  • Represented G & W Architects, Engineers, and Project Consultants Co. before the Court of Tax Appeals Division, En Banc, and with the Supreme Court of the Philippines in a challenge against the Bureau of Internal Revenue’s assessment amounting to $14m, securing a favourable decision.
  • Represented Island Quarry and Aggregates Corporation in the Court of Tax Appeals in relation to income tax, Value Added Tax, and Withholding Tax.

Gorriceta Africa Cauton & Saavedra

Spearheaded by Vincent Paul Saavedra  and Mark Gorriceta, the tax practice at Gorriceta Africa Cauton & Saavedra has substanial experience assisting domestic and multinational companies with the tax implications of their transactions, tax assessments, customs law compliance and cases filed before the Court of Tax Appeals. The group is also particularly effective at advising on cross-border tax planning involving high-value estates. Senior associate Dyan Angela de la Fuente is the standout practitioner for complex tax issues.

Other key lawyers:

Dyan Angela de la Fuente

Key clients

Manila Water Company

Xurpas, Inc.

NLEX Corp.

DM Wenceslao & Associates, Incorporated

Javier Project Managers, Inc.

Blue Aurora Solutions, Inc. (Flowerstore.ph)

Martinez Vergara & Gonzalez Sociedad

Martinez Vergara Gonzalez & Serrano’s ‘professional, knowledgeable and experienced‘ tax practice, which is jointly led by Rosalia S. Bartolome-Alejo and Mary Elizabeth Belmonte, stands out for its broad tax advisory and tax advocacy capabilities. Challenging assessments and claiming refunds from the Bureau of Internal Revenue, general tax planning, estate planning and settlements, as well as due diligence on projects and corporate transactions are among the key areas of strength for the department.

Other key lawyers:

Reynaldo Dizon

Testimonials

‘By working in teams, we are always in the loop and get timely updates on the project at hand.’

The MVGS team has very diverse legal expertise, has a very good network both in the private and public sectors.’

‘The MVGS team is very professional, knowledgeable and experienced. They offer very practical solutions to issues that we raise.’

Lawyers are accessible at any reasonable time to provide the necessary legal opinion. The law firm is backed up with a pool of competent, able and knowledgeable lawyers ready to take on the task and legal work assigned to them.’

Key clients

Lorenzo Development Corporation

Organisational Support Services, Inc.

Guild Securities, Inc.

Steniel Manufacturing Corporation

Work highlights

  • Represented Organisational Support Services Inc.  in its claims for refunds of excess and unutilized input value-added tax (VAT) on purchases of goods and services attributable to zero-rated sales of services for the period July 2018 to June 2019.
  • Represented Guild Securities, Inc. in its dispute against the assessment of the Bureau of Internal Revenue for the alleged deficiency VAT, expanded expanded withholding tax, final withholding tax, and compromise penalty for the taxable year 2017.
  • Advised Steniel Manufacturing Corporation on a share-swap transaction with three corporate entities and two individuals which qualifies as a tax-free exchange under Section 40(C)(2) of the Tax Code of 1997, as amended.

Disini & Disini Law Office

Disini & Disini Law Office distinguishes itself in the market by routinely advising online platforms, tech start-ups, software providers and fintech entities on the tax implications of their innovative products and services. The group handles the local and national tax dimensions of transactions and cross-border arrangements, and also has experience dealing with issues before the Bureau of Internal Revenue. JJ Disini, Rowena Disini and special counsel Ethel Maraon-Serate are the firm’s main tax advisers.

Practice head(s):

JJ Disini; Rowena Disini

Other key lawyers:

Ethel Maraon-Serate

Key clients

Tricog Health PTE. LTD.

DataOne Asia (Philippines), Inc.

Trusting Social AI Philippines

Kumu Inc.

Work highlights

  • Advised Tricog Health PTE. LTD on the restructure of a cross-border contract involving data processing in Singapore and India, allowing it to avail of favorable tax rates.
  • Advised an all-digital bank on the proper tax treatment for its novel and complex promos that were launched nationwide.
  • Advising a virtual asset service provider on setting up a death claims policy for its cryptocurrencies, which included tax issues.