Tax in Philippines

Angara Abello Concepcion Regala & Cruz Law Offices (ACCRALaw)

Angara Abello Concepcion Regala & Cruz Law Offices (ACCRALaw) stands out for its experience in advising prominent clients on tax litigation. A stand-out case for the practice is its representation of the Bangko Sentral ng Pilipinas, the Filipino central bank, in its dispute with the tax authority, a rare tax case involving a government entity. The team also advises clients on the tax implications of investments, as well as on succession and estate planning. The team is led by Ruby Rose Yusi, Eric Recalde, and Oliver Pantaleon.

Other key lawyers:

Francisco Lim

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.

Work highlights

  • Represented Bangko Sentral ng Pilipinas, the Philippine Central Bank, before the Court of Tax Appeals in a dispute with the tax authority relating to deficient tax assessments.
  • Represented Metropolitan Bank and Trust Company, et al. in a case against the Bureau of Internal Revenue, involving the legality of a tax regulation issued by the Bureau.
  • Acting as the tax counsel of Metropolitan Bank & Trust Company (MBTC), one of the Philippines’ biggest banks, in its claims as creditor of the insolvent ship-building company Hanjin Heavy Industries and Construction Philippines.

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

Gatmaytan Yap Patacsil Gutierrez & Protacio (C&G Law) advises multinationals and domestic companies on tax matters, including providing assistance with the tax implications of transactions as well as representing clients in disputing tax assessments. The practice is led by Anthony Gutierrez, who acts in both contentious and non-contentious taxation matters. Roxanne Tadique is another key contact in the team, and also has a broad practice.

Practice head(s):

Anthony Gutierrez

Other key lawyers:

Roxanne Tadique

Key clients

LafargeHolcim

Metro Rail Transit Corporation

Sanofi-Aventis Europe and Sanofi S.A.

Sanofi Pasteur, Inc.

Sanofi-Aventis Philippines Inc.

TeaM Energy

Therma South, Inc. (which is a member of the Aboitiz Group)

Holcim Philippines, Inc.

Work highlights

  • Advising LafargeHolcim on the most tax efficient way to repatriate its capital investment and accumulated profits in relation to a $2.15bn share sale.
  • Acting for Metro Rail Transit Corporation in proceedings before the Court of Tax Appeals (CTA), involving a disputed assessment issued by Bureau of Internal Revenue (BIR) for taxable year 2012 for taxes amounting to over $232m to $359m.
  • Assisted Sanofi-Aventis in determining the most tax efficient way to implement a reorganisation in the Philippines, including the transfer of shareholdings in affiliates in the country to affiliates in Europe.

Quisumbing Torres

Quisumbing Torres advises clients on high-value taxation matters, such as transactions and restructurings, as well as assisting with assessments and disputes with the Bureau of Internal Revenue and the Bureau of Customs. Working alongside other lawyers from the Baker McKenzie group, the team frequently advises multinationals. The team is also increasingly active in estate management. The practice is led by Ronald Bernas and Kristine Anne Mercado-Tamayo are also key contacts. Dennis Dimagiba retired from the practice in December 2020.

Practice head(s):

Ronald Bernas

Other key lawyers:

Kristine Anne Mercado-Tamayo

Key clients

Alphabet / Google Inc.

Pfizer Inc.

SyCip Salazar Hernandez & Gatmaitan

SyCip Salazar Hernandez & Gatmaitan has a broad tax practice, encompassing non-contentious tax advice, as well as acting for clients in challenging tax assessments from local governments and the Bureau of Internal Revenue. In addition to advising local companies, the team's client base also includes foreign corporations, which advises on tax matters as well as challenging decisions from the Bureau of Customs. The team is led by Hector De Leon, Russel Rodriguez, Ronald Mark Lleno and Carina Laforteza. Rolando Medalla has retired.

Key clients

Jobstreet.com Philippines, Inc.

Pueblo de Oro Development Corporation

Regal Ware, Inc.

Work highlights

  • Successfully represented Jobstreet Philippines in questioning before the Court of Tax Appeals (“CTA”) an assessment by the Bureau of Internal Revenue on the issue, among others, of the whether withholding of VAT should be made at the time of accrual of liability or at the time of payment of the fees.
  • Acted for Pueblo de Oro Development Corporation in filing a petition for review with the CTA questioning the assessment issued by the Bureau of Internal Revenue (BIR) on the grounds, among others, that the BIR did not do its own investigation of the taxpayer and merely relied on the findings of another government agency.
  • Assisted Regal Ware with facilitating the release from the Philippine Bureau of Customs (“BOC”) of its two containerised shipments which were initially held by the BOC because of a clerical error that resulted in a discrepancy between the consignee as stated in the inward shipping manifest and in the customs import entry.

Villaraza & Angangco (V&A Law)

Villaraza & Angangco (V&A Law) advises companies on the tax implications of restructurings, investments and joint ventures. Additionally, the team represents clients in challenging tax and custom assessments. The practice is led by Raoul Angangco, Sylvette Tankiang and Franchette Acosta, and frequently acts alongside partners from the firm's corporate department. Maria Concepcion Simundac and Kristin Charisse Siao are also key contacts in the team.

Key clients

China Telecommunications Corporation

Emperador Distillers, Inc.

Schweitzer-Mauduit International, Inc.

China Telecom Fufu Information Technology Co., Ltd.

EWP Philippines, Inc.

Abundance Providers and Entrepreneurs Corporation

InfinitusHealth Products (Philippines) Inc.

Blackpanda Philippines, Inc.

Work highlights

  • Acting for China Telecommunications Corporation in connection with the client’s investment in DITO Telecommunity Corporation (“DITO”) (formerly known as Mindanao Islamic Telephone Company, Inc. (“Mislatel”)), a consortium comprised of Udenna Corporation, Chelsea Logistics and Infrastructure Holding, Corp., and CTC., rendering various legal services including analysis and advice on the tax consequences of the client’s and DITO’s structuring of the entire transaction, investment schemes and financing of the joint venture.
  • Advising Emperador Distillers, Inc. (“EDI”) on a wide range of topics, including assistance with the documentary stamp tax implications of the proposed amendments to agreements pertaining to equity-linked securities for Emperador, Inc., and the capability of EDI’s subsidiaries to enter into e-commerce business of on-demand liquor delivery service without contradicting the Retail Trade Liberalization Act.
  • Provided legal advice on the tax-efficient structuring options available to the Client in connection with the PhP3 billion corporate restructuring of its subsidiary, which addressed issues on capital gains tax, donor’s tax, documentary stamp tax (“DST”), income tax, and requirements for compliance. Assisted in navigating the regulatory landscape for the selling of the Client’s shares in its subsidiary by advising on matters dealing with the Share Purchase Agreement and its tax implications, as well as assisted in the preparation of the necessary documentary requirements and securing the necessary government approvals. The excess capital of the Client’s subsidiary was repatriated to the Client’s main office.

Zambrano Gruba Caganda & Advincula

Zambrano Gruba Caganda & Advincula stands out for its experience in contentious tax matters, frequently representing clients before the Court of Tax Appeals and the Supreme Court. In addition to acting for companies based in the Philippines, the team also acts for multinationals; its ability to do so is bolstered by its membership of the WPG Law Network. The team is also active in non-contentious matters. The practice is led by Lily Gruba, Antero Jose Caganda, Angelo Patrick Advincula, Jorge Alfonso Melo, and Juan Miguel Victor De La Fuente.

Key clients

Sabre Travel Network (Philippines) Inc.

G & W Architects, Engineers and Project Consultants Co.

Asia United Leasing and Finance Corporation

Lucio L. Co, Susan P. Co, Ferdinand P. Co, and Pamela Justine P. Co

Philippine Airlines, Inc.

Island Quarry and Aggregates Corporation

Grand Plaza Hotel Corporation

Work highlights

  • Secured a favourable decision for Philippine Airlines from the Supreme Court of the Philippines concerning the client’s assessments for excise taxes on importations of aviation fuel used by the client for its domestic airline operations.
  • Acted for G & W Architects, Engineers and Project Consultants Co. in securing a favourable decision for the client before the Court of Tax Appeals Division, En Banc, and with the Supreme Court of the Philippines against the Bureau of Internal Revenue’s assessment amounting to USD 14,000,000.00. Also handled the representation and legal defence of the client before the Court of Tax Appeals on assessments for deficiency expanded withholding tax and Documentary Stamp Tax amounting to USD 10,600,000.00.
  • Successfully represented Island Quarry and Aggregates Corporation in securing a favourable decision from the Court of Tax Appeals En Banc concerning the client’s deficiency Income Tax, Value Added Tax, and Withholding Tax amounting to USD 933,898.75.

Du-Baladad & Associates

A boutique tax law firm, Du-Baladad & Associates handles contentious tax matters including assessments, disputes, and tax claims, as well as tax planning. The firm's client base is especially focused on companies in the banking, energy, mining, and technology sectors. Founder Benedicta Du-Baladad leads the team.

Martinez Vergara Gonzalez & Serrano

Led by Rosalia Bartolome-Alejo, Martinez Vergara Gonzalez & Serrano’s tax practice handles tax planning and disputes involving national and local authorities. The practice additionally acts cross-departmentally to handle the tax aspects of transactions. The team is also increasingly active in estate planning, and has expanded recently with the additions of associates Mary Elizabeth Belmonte and Harlem P. Ma-at.

Practice head(s):

Rosalia Bartolome-Alejo

Key clients

Torre Lorenzo Development Corporation

Three Point Star Holdings, Inc.

Work highlights

  • Acted as counsel to Three Point Star on the acquisition of a two-hectare land situated in Parañaque City through a public auction conducted by Parañaque City, and guided the company in the payment of all national and local taxes in connection with the acquisition and the review of all applicable laws, ordinances, and regulations on the tax treatment of the acquisition of the abandoned land.
  • Assisted Torre Central Condominium Corporation (“Torre Central”), a condominium corporation under management by Torre Lorenzo Development Corporation, in a local taxation-related dispute with the City of Manila relating to the improper imposition of zoning fees by a local government unit.

Platon Martinez Flores San Pedro & Leaño

Led by Hector Martinez, Platon Martinez Flores San Pedro & Leaño represents prominent companies in tax assessments. The team’s client base includes both local companies and multinationals. Mia Carissa Martin is the other key partner in the team.

Quiason Makalintal Barot Torres Ibarra Sison & Damaso

Led by Wilfrido Sanchez, Quiason Makalintal Barot Torres Ibarra Sison & Damaso handles tax planning for companies as well as estate planning for individuals. The team also advises on tax returns as well as the implications of changes to tax law.

Romulo Mabanta Buenaventura Sayoc & De Los Angeles

Romulo Mabanta Buenaventura Sayoc & De Los Angeles' tax practice advises on the tax implications of corporate transactions and reorganisations, as well as handling tax planning and litigation.

Siguion Reyna, Montecillo & Ongsiako

Siguion Reyna, Montecillo & Ongsiako handles tax advisory and disputes work, including assisting with the tax implications of transactions as well as contesting tax assessments made at the local and national level. The team also assists international firms with avoiding double taxation under tax treaties. Ferdinand Hidalgo is the key contact.

Castillo Laman Tan Pantaleon & San Jose

Castillo Laman Tan Pantaleon & San Jose handles tax work including advice on transactions and succession planning, as well as handling disputes with the Bureau of Internal Revenue. Victoria Sarmiento is the key practitioner.

Ocampo Manalo Valdez & Lim

Ocampo Manalo Valdez & Lim's tax practice handles corporate and individual tax planning as well as disputes in the Court of Tax Appeals.

Picazo Buyco Tan Fider & Santos

Picazo Buyco Tan Fider & Santos provides contentious and non-contentious tax advice, including assisting with estate planning and representing clients in disputes with the Bureau of Internal Revenue.

Poblador Bautista & Reyes

Poblador Bautista & Reyes's work on taxation includes representing clients contesting tax assessments in the Court of Tax Appeals, as well as acting for clients in claims for tax refunds. Meghan de Guia leads the practice.

Practice head(s):

Meghan G. de Guia

Key clients

Metro Rail Transit Corporation

Energy Development Corporation

Petron Corporation

Asian Hospital, Inc.

Work highlights

  • Representing the owner/lessor of a major rail transit system in Metro Manila (the LRTS Phase I) in its appeal to the Court of Tax Appeals on tax deficiency assessments of the Bureau of Internal Revenue amounting to billions of pesos. Also represented client in a separate arbitration proceeding against the Philippine Government’s Department of Transportation (DOTr) and secured declaratory judgment for DOTr to reimburse client for real estate taxes it has paid, for any assessment of income tax (USD115 million or Php6 billion), value-added tax (USD74.3 million or Php3.9 billion), penalties for late payment of income taxes (USD23.7 million or Php1.25 billion), and other taxes (USD27.36 million or Php1.4 billion).
  • Acted for a leading renewable energy company in filing protests to question the refusal of local government units to comply with the special realty tax rates granted, as incentive, to companies engaged in renewable energy development.
  • Advised an oil refining company in filing claims for the refund of excise taxes assessed based on the misapplication of the provisions of the National Internal Revenue Code.