BIR Issuances

Tax brief
March 2014

Court Decisions

DOF Orders

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Contents
BIR Issuances
02 Extended notification period for exchange of
information
02 Clarification on registration and compliance
requirements of marginal income earners
03 Presentation of tax exemption certificate or ruling
as proof of exemption from withholding tax
03 Deferral of ITR disclosure requirement
04 Clarification on the due process requirement in the
issuance of deficiency tax assessment
05 Guidelines on accreditation of importers and
customs brokers
06 Transitory provisions
Court Decisions
07 IEIRD as proof of payment of input VAT on
importations
08 Taxation of representative offices
09 Non-issuance of PAN violates due process
09 Simultaneous imposition of LBT and franchise tax
DOF Orders
10 10-year retention period for customs records
11 Revised rules on the accreditation of importers
12 Provisional lifting of suspension of importers
accreditation
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13 Request for tax ruling

BIR Issuances

Court Decisions

DOF Orders

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BIR Issuances

Extended notification period for

exchange of information

The Bureau of Internal Revenue

(BIR) has extended the period during
which a taxpayer should be notified
in writing by the Commissioner
of Internal Revenue (CIR) that a
foreign tax authority is requesting
for exchange of information held
by financial institutions pursuant
to an international convention or
agreement.
The notification by the CIR should
be made within 60 days from
receipt of request from the foreign
tax authority for exchange of
information. However, if notification
within the 60-day period will
undermine the chances of success of
the investigation conducted by the
requesting foreign tax authority, the
taxpayer may be notified of such
request for a maximum period of six
months from receipt of the request.
(Revenue Regulations No. 3-2014,
February 11, 2014)

Clarification on registration and

compliance requirements of
marginal income earners

The BIR issued the following

clarifications on the registration
and compliance of marginal income
earners.

sari-sari stores, small carinderias or

turo-turos, drivers/operators of a
single unit tricycle, and others. It
should not, however, include licensed
professionals, consultants, artists,
sales agents, brokers and other similar
individuals, and all others whose
revenue is subject to withholding tax.

A. Definition and coverage of

marginal income earners
A marginal income earner (MIE) is an
individual not deriving compensation
as an employee under an employeremployee relationship but who is
self-employed and deriving gross
sales or receipts not exceeding
P100,000 in any 12-month period. To
be considered an MIE, the activity
of the individual should be for
subsistence or livelihood.
The term marginal income earner
shall include, but shall not be
limited to, agricultural growers/
producers (farmers/fishermen)
selling directly to consumers, small

B. Registration and compliance

requirements
A marginal income earner is
required to register with the BIR
but with minimum registration and
compliance requirements, as follows:
1. Registration with the BIR
using BIR Form 1901 with the
following minimal documentary
requirements: (a) sworn statement
of income for the year; and (b)
National Statistics Office (NSO)
certified or Local Civil Registry
Birth Certificate

2. Exemption from payment of

Annual Registration Fee (ARF)
3. Registration of books of accounts
(e.g., two-column journal or
other simplified books for daily
expenses and revenues)
4. Issuance of registered principal
receipts/sales invoices as
prescribed under Revenue
Memorandum Order No.
(RMO) 12-2013
5. Filing and payment of annual
income tax return (BIR Form
1701)
6. Exemption from payment
of business taxes (VAT and
percentage tax)
(Revenue Memorandum Circular No.
7-2014, February 5, 2014)

March 2014 2

BIR Issuances

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DOF Orders

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BIR Issuances

Presentation of tax exemption

certificate or ruling as proof of
exemption from withholding tax

All individuals and entities claiming

exemption from income tax and,
consequently, from withholding taxes
shall provide a copy of their valid,
current and subsisting tax exemption
certificate or ruling to their client
before payment of the income. The
certificate or ruling issued by the
taxpayer must explicitly recognize
the grant of tax exemption and the
corresponding exemption from
withholding tax.
Failure to present the tax exemption
certificate or ruling shall subject
the taxpayer to the payment of
appropriate withholding taxes due
on the transaction. On the other
hand, the failure of the income payor
(client) as withholding agent to
withhold notwithstanding the lack
of tax exemption certificate or ruling

shall subject the agent to penalties

applicable to non-withholding of
taxes under Section 251 and other
pertinent provisions of the Tax Code.
(Revenue Memorandum Circular 8-2014,
February 6, 2014)
Deferral of ITR disclosure
requirement

The BIR has made optional

the disclosure of supplemental
information in the income tax returns
(BIR Form 1700 and 1701), which
individual taxpayers are required to
file on or before April 15, 2014.

BIR advised individual taxpayers

to demand from their payors, and
properly document, their BIR Form
2307 and other pieces of evidence for
final taxes withheld. They should also
properly receipt and book their taxexempt income.
The BIR also clarified that in the
filing of tax returns, individual
taxpayers may use their (a)
community tax certificate, (b)
passport, or (c) drivers license.
(Revenue Memorandum Circular No.
9-2014, February 11, 2014)

The disclosure requirement, however,

shall become mandatory for income
tax filing covering and starting
calendar year 2014, for which a return
is required to be filed in 2015. In
preparation for the implementation
of the disclosure requirement, the

March 2014 3

BIR Issuances

Court Decisions

DOF Orders

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BIR Issuances

Clarification on the due process

requirement in the issuance of
deficiency tax assessment

The BIR issued the following

clarification on the due process
requirement introduced by Revenue
Regulations No. (RR) 18-2013 to
12-99.
Authorized Representatives of
the CIR

The duly authorized

representatives of the CIR who shall
issue the Preliminary Assessment
Notice (PAN), Formal Letter of
Demand (FLD)/Final Assessment
Notice (FAN) refers to Revenue
Regional Directors, Assistant
Commissioner Large Taxpayers
Service, and Assistant Commissioner
Enforcement and Advocacy Service.
Taxpayers shall also submit/file their
response to the PAN and protests
(requests for reconsideration/
reinvestigation) to the FLD/
FAN with the duly authorized

representatives who signed the PAN

and FLD/FAN. Protests in the nature
of requests for reconsideration arising
from inactions or adverse decisions of
the duly authorized representatives
shall be filed with the Office of the
Commissioner.
A taxpayer may make voluntary
payments of its probable deficiency
taxes and penalties even prior to the
issuance of a PAN.

Effect of issuance of FAN/FLD

beyond 15 days after filing of PAN

An FLD/FAN issued beyond 15

days from the filing/submission of
the taxpayers response to the PAN
shall be valid provided it is issued
within the prescribed period to assess
internal revenue taxes. However, the
non-observance of the 15-day period
shall constitute an administrative
infraction, which will subject the
revenue officers who caused the delay
to administrative sanctions.

Denial of response to PAN and

protest to FLD/FAN

Non-submission of supporting

An FLD/FAN reiterating the

immediate payment of deficiency
taxes and penalties previously made
in the PAN is a denial of the response
to the PAN. On the other hand, a
final demand letter for payment of
delinquent taxes may be considered a
decision on a disputed assessment.

documents in support of request

the FLD/FAN by the introduction

of newly discovered or additional
evidence because it/he is deemed to
have lost his/its chance to present
this evidence. The BIR shall deny the
request for reinvestigation through
the issuance of a Final Decision on
Disputed Assessment (FDDA) .
Service of assessment notices

The notice (PAN/FLD/FAN/

FDDA) shall first be served to the
taxpayers registered address before
the same may be served to the
taxpayers registered address and
known address simultaneously.

for reinvestigation

Failure of the taxpayer who requested

for a reinvestigation to submit all
relevant supporting documents
within the 60-day period shall render
the FLD/FAN final by operation
of law. The taxpayer shall be barred
from disputing the correctness of

(Revenue Memorandum Circular No. 112014, February 19, 2014)

March 2014 4

BIR Issuances

Court Decisions

DOF Orders

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BIR Issuances

Guidelines on accreditation of
importers and customs brokers

All importers and customs

brokers (individuals, partnerships,
corporations, cooperatives,
associations -- whether taxable
or non-taxable), unless otherwise
exempted, are required to secure
accreditation from both the BIR and
the Bureau of Customs (BOC).
As the first phase of the accreditation
process, all importers and customs
brokers should secure accreditation
from the BIR. BIR-accredited
importers and customs brokers
shall be issued BIR Importer
Clearance Certificates (BIRICCs) and BIR Customs Broker
Clearance Certificates (BIR-BCCs),
respectively, which shall be presented
to the BOC for the second phase of
the accreditation.

In the second and final phase,

importers and brokers will be subject
to BOC accreditation under the rules
and regulations to be issued by the
BOC.
A. BIR accreditation criteria
In order to be accredited by the
BIR, importers and customs
brokers should satisfy the following
accreditation criteria:
1. Existence, at all times, of a Head
Office (HO) or principal place
of business for the conduct of
business operations
2. Full compliance with all
the primary and secondary
registration requirements of the
BIR
3. No stop-filer cases with the
BIR, or timely filing of the
required tax returns and payment
of the taxes

4. No record of any account

receivable/delinquent account
with the BIR

8. No material misrepresentation
in the documents submitted in
applying for accreditation

5. No record of any pending

criminal complaint filed by the
BIR for tax evasion and other
criminal offenses under the Tax
Code, whether filed in court or
with the Department of Justice,
or subject of final and executory
judgment by court

9. Regular use of the eFiling and

Payment System (eFPS) in filing
all the requisite tax returns and
in the payment of the taxes due
thereon; or regular use of the
Interactive Forms (IAF) system in
filing all the requisite tax returns,
and once the IAF payment feature
is operational, in the payment of
the taxes due thereon

6. No unresolved issues arising

from discrepancies in the
declared income or expenses
resulting from the matching of
third-party information from
the Reconciliation Lists for
Enforcement (RELIEF) system
and Tax Reconciliation System
(TRS)

10. Regular submission of all

information returns required
under existing internal revenue
tax laws, rules, regulations,
and issuances (e.g., Summary
Lists of Sales, Purchases and
Importations), alphalists, etc.

7. Not tagged as a Cannot Be

Located (CBL) taxpayer

March 2014 5

BIR Issuances

Court Decisions

DOF Orders

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BIR Issuances

B. Procedures and guidelines

All applications for accreditation
shall be filed directly and by personal
appearance with the Accounts
Receivable Monitoring Division
(ARMD) using the prescribed
application form and together with all
the required supporting documents.
All applicants for accreditation shall
pay a non-refundable processing
and certification fee of P2,000. The
application should be processed
within 15 working days from
acceptance of the application form
and complete supporting documents
and upon receipt of the written report
bearing the results of verification with
other BIR offices.
In case of approved applications, the
ARMD shall prepare and issue the
BIR Importer Clearance Certificate
or BIR Customs Broker Clearance

Certificate. The certificate shall

be valid for a period of three years
from date of issuance, unless sooner
revoked or cancelled.
In case of denied applications, the
ARMD shall prepare and issue a
Notice of Denial of Application for
Accreditation as an Importer/Broker
(BIR-NDAIB).
The issuance of a BIR-NDAIB is
without prejudice to the importer or
customs brokers filing of another
application for accreditation when the
circumstances that lead to the denial
of the previous application no longer
exist.

Transitory provisions

Valid accreditation certificates issued

by the BOCs ICARE Unit prior to
the effectivity of RMO 10-14 shall
remain valid until their expiry dates.
Holders thereof are required to file
their applications for renewal of
accreditation with the BIR at least
three months prior to the expiry date.
Upon the effectivity of Department
of Finance Order (DO) No. 122014, pending applications for new
accreditation filed with the BOCs
ICARE Unit shall be transmitted to
the BIR. The ARMD shall prioritize
the processing of all pending
applications transmitted by the BOC.
Given that their processing shall be
covered by the new accreditation
policies and procedure under the
Order, the ARMD shall immediately
notify the concerned applicants
of any incomplete or lacking

requirements to be submitted within

15 working days from receipt of the
notice. Otherwise, the application
shall be denied.
Pending applications for renewal of
accreditation filed with the BOCs
ICARE Unit until the date of
effectivity of DO No. 12-2014 shall
continue to be processed by the
BOC. Upon effectivity of the DO, all
applications for renewal shall be filed
with the BIR.
Applications for renewal of
accreditation filed by importers
and customs brokers with expired
accreditation certificates issued by the
BOC shall be treated by the BIR as
new applications for accreditation.
(Revenue Memorandum Order No. 102014, February 11, 2014)

March 2014 6

BIR Issuances

Court Decisions

DOF Orders

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Court Decisions

IEIRD as proof of payment of

input VAT on importations

Under Section 110(A) and 113(A)

of the Tax Code, any input tax that
is credited against output VAT or is
a subject of claim for refund must
be evidenced by a VAT invoice or
official receipt. In case of importation
of goods or properties, Section
4.110-8 of RR 16-05, as amended,
provides that these should be
supported by import entry or other
equivalent documents showing actual
payment of VAT on the imported
goods.
In the instant case, the taxpayer
sought refund of its unutilized input
VAT attributable to its zero-rated
sales. To substantiate its excess input
VAT, the taxpayer presented the VAT
official receipts and invoices issued
by its suppliers, and import entry and
internal revenue declaration (IEIRD)
as proof of payment of duties and
taxes on its importations. Upon

reaching the Court of Tax Appeals

(CTA) in Division, the taxpayers
claim for refund was denied on the
ground that the IEIRDs supporting
excess input taxes on importations
were not machine validated.
In its decision on appeal, the CTA
en banc held that while Sections
110(A) and 113(A) of the Tax Code,
as implemented by Sections 4.110-8
and 4.113-1 of RR 16-05, do not
require the IEIRD to be machine
validated, paragraphs 2.3 and 2.3.1 of
Customs Administrative Order No.
2-95 (September 8, 1995) require that
IERDs be machine validated as proof
of payment.

the imported goods . Based on the

foregoing, actual payment of VAT on
imported goods can be shown only
if the IEIRDs are machine validated.
Considering that the IEIRDs were
not machine validated, the CTA en
banc held that actual payment could
not have been made by the taxpayer.
Hence, it denied the claim of the
taxpayer for refund of its unutilized
input VAT on importations
supported by IERDs without
machine validation.
(Philex Mining Corporation v.
Commissioner of Internal Revenue, CTA
EB Case No. 939 re: CTA Case No.
8044, February 12, 2014)

As explained by the CTA en banc,

under Sections 110(A) and 113(A)
of the Tax Code, importation of
goods must be supported by import
entry or other equivalent document
showing actual payment of VAT on

March 2014 7

BIR Issuances

Court Decisions

DOF Orders

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Court Decisions

Taxation of representative offices

A representative office that

undertakes promotion of the parent
company is not liable as a regional
operating headquarter (ROHQ)
subject to 10% tax under Section
34(A)(1)(b) of the Tax Code.
The CTA held that it is erroneous
to tax a representative office as
an ROHQ since the office is
only involved in information
dissemination/product promotion,
and unlike an ROHQ, it does not
conclude contracts on behalf of the
parent company.
As defined, an ROHQ is a foreign
business entity that is allowed to
derive income in the Philippines by
performing qualifying services to its
affiliates, subsidiaries or branches in
the Philippines, in the Asia-Pacific
region, and in other foreign markets.

In the instant case, the representative

office deals with clients of the parent
company and does not deal with its
affiliates, subsidiaries or branches.
It is fully subsidized by the head
office and it basically undertakes
information dissemination and
product promotion, and acts as a
liaison/coordinating office between
the local clients and the head office.
These are allowed activities of a
representative office. It does not
conclude contracts of local clients on
behalf of its parent company.
The subsidy received by the
representative office is in the form of
foreign inward remittances from its
head office abroad, which is utilized
to cover its expenses. The CTA held
that the foreign inward remittances
received by a representative office
could not be considered income
or flow of wealth, but a subsidy.
A subsidy represents a capital or
fund that is distinct from income. It
follows that the representative offices

unspent remittances, which must be

considered a mere subsidy, should
not be considered income subject to
Philippine income tax.
The CTA further held that the
undeclared income arising from
subsidy and disallowances of
expenses of the representative offices
should not be subject to VAT under
Sections 105 and 108 of the Tax
Code. According to the CTA, the
VAT was assessed by the BIR on
the assumption that the undeclared
income under adjustments/
disallowances in its deficiency
income tax assessment was taxable
income. The CTA held that the
adjustments and disallowances were
not shown to be flow of wealth
or taxable income. Hence, the same
should not be subject to VAT.
(Shinko Electric Industries Co., Ltd., v.
Commissioner of Internal Revenue, CTA
Case No. 8213, February 10, 2014)

March 2014 8

BIR Issuances

Court Decisions

DOF Orders

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Court Decisions

Non-issuance of PAN violates due

process

Under Section 228 of the Tax

Code, the BIR Commissioner, after
finding that proper taxes should
be assessed, must issue a notice of
her findings to the taxpayer in the
nature of a PAN. According to the
CTA, save in cases where a prior
notice of assessment is not required,
the PAN is a vital component or an
indispensable requirement before the
BIR Commissioner can issue a FAN
or an FLD.
In the present case, the taxpayer
denied the receipt of the PAN
in relation to the deficiency tax
assessment issued against it by the
BIR. As the taxpayer categorically
denies receipt of the PAN, it is
incumbent upon the BIR to prove by
competent evidence that indeed the
taxpayer received the PAN. The type
of evidence that may be presented to

prove that PAN was received by the

taxpayer includes copy of registry
return and/or certification from the
post office.
Considering that the BIR did not
offer any document to prove that the
PAN was received by the taxpayer,
the CTA found that the taxpayer
was not accorded due process in
the issuance of the assessment.
Accordingly, the CTA cancelled
the deficiency tax assessment issued
against the taxpayer
(SVI Information v. Commissioner of
Internal Revenue, CTA Case No. 8496,
February 10, 2014)

Simultaneous imposition of LBT

and franchise tax

No double taxation exists when

a local government unit (LGU)
imposes a local business tax and
franchise tax, notwithstanding that
both are based on gross receipts
and sales of the same taxpayer. For
there to be double taxation, which
is prohibited by the Constitution,
the CTA held that two taxes must be
imposed on the same subject matter,
for the same purpose, by the same
taxing authority, within the same
jurisdiction, during the same taxing
period, and they must be of the same
kind or character.
In the instant case, a cable company
was assessed for franchise tax, in
addition to local business tax. The
CTA ruled that while the local
business tax and franchise tax are
both based on gross receipts and
sales of taxpayers, there is no double
taxation since the local business tax

and the franchise tax are different in

terms of their nature or character.
As to its nature and character, the
local business tax is imposed on the
privilege of engaging in the business
while a franchise tax is imposed for
the exercise of enjoying a franchise.
Moreover, the concerned LGU has
the power to impose both local
business tax and franchise tax under
Sections 151 and 137, respectively,
under the Local Government Code
(LGC), as amended. It was by virtue
and pursuant to the provisions of
the LGC that the concerned LGU
derived its authority to impose both
the local business tax and franchise
tax under its duly enacted local
revenue ordinance.
(Sky Cable Corporation v. Quezon City,
CTA AC No. 102, February 10, 2014)

March 2014 9

BIR Issuances

Court Decisions

DOF Orders

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DOF Orders

10-year retention period for

customs records

All importers should keep at their

place of business, for a period of
10 years from the date of filing of
the import entry, all the records of
their importations and/or books of
accounts, business and/or computer
systems and all other customs
commercial data, in whatever form,
including payment records relevant
for the verification of the accuracy
of the transaction declared by the
importers/customs brokers on the
import entry and other documents.
The following are the records that
should be kept by importers:
a) Company entity or structure
(e.g., Articles of Incorporation,
organizational structure, capital
composition, stock and transfer
book, and others)

b) Ordering and purchase

documents
c) Shipping, importation,
exportation and transportation
documents
d) Manufacturing, stock and resale
documentation
e) Bank documents, financial
statements and other accounting
information

Similarly, customs brokers are also

required to keep for a period of 10
years from the date of importation,
the copies of the importation
records in whatever form covering
transactions that they handle,
including shipping, importation,
exportation, and transportation
documents such as import and/
or export entry, invoices and/or
consignment notes, etc.
(Department of Finance Order No. 0112014, February 5, 2014)

f) Charts and codes of accounts,

ledgers, financial statements,
accounting instruction manuals,
and systems and program
documentation
g) Papers, books, registers, discs,
films, tapes, soundtracks and
other devices in or on which
information on importations and
others are recorded or stored

March 2014 10

BIR Issuances

Court Decisions

DOF Orders

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Revised rules on the accreditation

of importers

The BIR, upon filing of an

application, shall issue the necessary
BIR-ICC in favor of an importer,
subject to the documentary
requirements and verification
procedures under the rules and
regulations to be promulgated by the
CIR.

accreditation of the importer. For

the procedures to be followed in
the accreditation of the importers,
the Commissioner of Customs
shall issue the necessary rules and
regulations for: (a) the registration
of importers accredited by the BIR
without the need for renewal or
additional accreditation process; and
(b) the suspension, revocation or
cancellation of the importers customs
accreditation in case of violation of
customs law and regulations. The
BOC shall likewise prescribe the
rules for risk profiling and the criteria
for classification of importers.

The BIR-ICC secured by the

importer must be presented to
the BOC, which shall process the

Both the Commissioners of Internal

Revenue and Customs are required
to issue the necessary rules and

As a pre-requisite for issuance of

BOC accreditation, all importers
must first secure a BIR-ICC as
part of the revised rules on the
accreditation of importers.

regulations within 15 days from the

issuance of the Order. All importers
shall be given 90 days from the
issuance of the rules and regulations
to comply with the accreditation;
otherwise, the accreditation of
the importer shall be deemed
automatically expired upon lapse of
the 90-day period.
(Department of Finance Order No. 0122014, February 6, 2014)

March 2014 11

BIR Issuances

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DOF Orders

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Provisional lifting of suspension

of importers accreditation

The Department of Finance (DOF)

has issued the guidelines on the
provisional lifting of the suspension
of accreditation of importers, which
was pending as of December 2013.
The requests for lifting of suspension
of importers accreditation shall be
processed and evaluated by the DOF
- Fiscal Intelligence Unit (FIU) to
whom the functions of the BOCPost Entry Audit Group (PEAG),
which suspended the importers
accreditation, were transferred under
Executive Order No. 155, series of
2013.

In determining the propriety of

request for provisional lifting
of the suspension of importers
accreditation, the DOF-FIU shall
refer to the guidelines and criteria
to be issued by the BIR (RMO 102014) pursuant to Department Order
No. 012-2014 requiring importers
to secure a BIR-ICC, prior to being
accredited by the BOC.
Based on compliance of the importer
with the prescribed guidelines under
RMO 10-2014, the DOF-FIU shall
make the necessary recommendation
to the BOC on whether the
suspension of importer accreditation
should be lifted or not.

In case the suspension of the

importers accreditation is
provisionally lifted, the same shall be
valid for 60 days from the date the
decision of the BOC is received by
the importer. Should the prescribed
60-day provisional lifting of
suspension lapse without any further
action from the DOF-FIU and/or
the BOC, the suspension shall be
permanently lifted.
(Department of Finance Order No. 0132014, February 6, 2014)

March 2014 12

BIR Issuances

Court Decisions

DOF Orders

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Request for tax ruling

We prepare and file, for and on behalf

of our clients, requests for rulings
to confirm the proper tax treatment
of certain business structures and
transactions. Requests for rulings
are generally required in the case of
tax-free exchange of assets for shares
of stock; application of preferential
rates of withholding taxes on income
payments to nonresident aliens and
foreign corporations pursuant to tax
treaties; entitlement to tax exemption

under Section 30 of the Tax Code;

and other transactions whose tax
treatment is not clearly provided
in the Tax Code, implementing
regulations, or other issuances of the
BIR or the DOF.

If you would like to know more about our request for tax
ruling services, please contact:

Oliver Beltran
Manager
Tax Advisory and Compliance
T + 632 988 2288 ext. 538
F + 632 886 5506
E Oliver.Beltran@ph.gt.com

March 2014 13

Tax Brief is a regular publication of Punongbayan & Araullo (P&A) that

aims to keep its clientele, as well as the general public, informed of various
developments in taxation and other related matters. This publication is not
intended to be a substitute for competent professional advice. Even though
careful effort has been exercised to ensure the accuracy of the contents of
this publication, it should not be used as the basis for formulating business
decisions. Government pronouncements, laws, especially on taxation, and
official interpretations are all subject to change. Matters relating to taxation,
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We welcome your suggestions and feedback so that the Tax Brief may be made
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and if it would help you to have the full text of the materials in the Tax Brief.
Lina Figueroa
Principal, Tax Advisory and Compliance Division
T +632 988-2288 ext. 507
F +632 886-5506
E Lina.Figueroa@ph.gt.com

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