Lawyerly

You're currently signed in as:
User

CIR v. CEBU TOYO CORPORATION

This case has been cited 5 times or more.

	GR No. 187485 2013-02-12	CIR v. SAN ROQUE POWER CORPORATION CARPIO, J.
SO ORDERED.[20]
	GR No. 157594 2010-03-09	TOSHIBA INFORMATION EQUIPMENT v. CIR LEONARDO-DE CASTRO, J.
The Court will not lightly set aside the conclusions reached by the CTA which, by the very nature of its functions, is dedicated exclusively to the resolution of tax problems and has accordingly developed an expertise on the subject unless there has been an abuse or improvident exercise of authority.[65] In Barcelon, Roxas Securities, Inc. (now known as UBP Securities, Inc.) v. Commissioner of Internal Revenue,[66] this Court more explicitly pronounced -
	GR No. 178090 2010-02-08	PANASONIC COMMUNICATIONS IMAGING CORPORATION OF PHILIPPINES v. CIR ABAD, J.
This Court will not set aside lightly the conclusions reached by the CTA which, by the very nature of its functions, is dedicated exclusively to the resolution of tax problems and has accordingly developed an expertise on the subject, unless there has been an abuse or improvident exercise of authority.[17] Besides, statutes that grant tax exemptions are construed strictissimi juris against the taxpayer and liberally in favor of the taxing authority. Tax refunds in relation to the VAT are in the nature of such exemptions. The general rule is that claimants of tax refunds bear the burden of proving the factual basis of their claims. Taxes are the lifeblood of the nation. Therefore, statutes that allow exemptions are construed strictly against the grantee and liberally in favor of the government.[18]
	GR NO. 166732 2007-04-27	INTEL TECHNOLOGY PHILIPPINES v. CIR CALLEJO, SR., J.
Based on the above provision, export sales, or sales outside the Philippines, are subject to VAT at 0% rate if made by a VAT-registered person.[58] When applied to the tax base, the 0% rate obviously results in no tax chargeable against the purchaser. The seller of such transactions charges no output tax, but can claim a refund or tax credit certificate for the VAT previously charged by suppliers.[59]
	GR NO. 150154 2005-08-09	CIR v. TOSHIBA INFORMATION EQUIPMENT CHICO-NAZARIO, J.
The rule that any sale by a VAT-registered supplier from the Customs Territory to a PEZA-registered enterprise shall be considered an export sale and subject to zero percent (0%) VAT was clearly established only on 15 October 1999, upon the issuance of RMC No. 74-99. Prior to the said date, however, whether or not a PEZA-registered enterprise was VAT-exempt depended on the type of fiscal incentives availed of by the said enterprise. This old rule on VAT-exemption or liability of PEZA-registered enterprises, followed by the BIR, also recognized and affirmed by the CTA, the Court of Appeals, and even this Court,[30] cannot be lightly disregarded considering the great number of PEZA-registered enterprises which did rely on it to determine its tax liabilities, as well as, its privileges.