WEEKLY TAX UPDATES [January 09, 2026]

BIR almost done with proposed reforms in tax audit process [Philippine Daily Inquirer, January 9, 2026]

According to Mendoza, the main drive is to address complaints about multiple LOAs being issued by different offices and officers within the BIR.

https://newsinfo.inquirer.net/2165029/bir-almost-done-with-proposed-reforms-in-tax-audit-process

‘Green lane’ investments climb to P6.11 trillion, says BOI [Philippine Daily Inquirer, January 9, 2026]

Among foreign investors, Denmark topped the list with P472.46 billion, followed by the Netherlands with P336.93 billion, Switzerland with P317.07 billion, Singapore with P299.44 billion, and Malaysia with P156.18 billion.

https://business.inquirer.net/568044/green-lane-investments-climb-to-p6-11t-says-boi

Clark semiconductor workers cited as key to global supply chains [The Manila Times, January 8, 2026]

CDC President and CEO Agnes Devanadera said the precision work of semiconductor employees in Clark directly supports global manufacturing and technology systems, ensuring safety, reliability and operational continuity across industries.

https://www.manilatimes.net/2026/01/08/regions/clark-semiconductor-workers-cited-as-key-to-global-supply-chains/2254696

DAR revokes land titles from some CLOA beneficiaries over premature leasing, selling [GMA News Online, January 8, 2026]

The Republic Act No. 6657 or the Comprehensive Agrarian Reform Law prohibits the sale or lease of lands awarded to ARBs for 10 years from the date of the CLOA or land title’s registration.

https://www.gmanetwork.com/news/money/economy/972157/dar-revokes-land-titles-from-some-cloa-beneficiaries-over-premature-leasing-selling/story/

Philippines invites Japan to build five new Teresa Magbanua-class patrol vessels for Coast Guard [Army Recognition, January 7, 2026]

As reported by Herbie_atX, on January 5, 2026, the Philippine Department of Transportation formally invited the Japanese company Mitsubishi Shipbuilding to construct the next batch of five Teresa Magbanua-class patrol vessels for the Philippine Coast Guard following a new bid opening. The 97-meter Multi-Role Response Vessels (MMRVs) are part of Phase III of the Maritime Safety Capability Improvement Project, financed mainly through a loan from the Japan International Cooperation Agency, and will expand the Coast Guard’s large offshore patrol fleet from two to seven ships.

https://www.armyrecognition.com/news/navy-news/2026/philippines-invites-japan-to-build-five-new-teresa-magbanua-class-patrol-vessels-for-coast-guard

Ayala sale of 40% stake in AC Logistics gets PCC clearance [Philippine Daily Inquirer, January 7, 2026]

The conglomerate is selling part of AC Logistics to an investment vehicle of Danish logistics giant AP Moller.

https://business.inquirer.net/567766/ayala-sale-of-40-stake-in-ac-logistics-gets-pcc-clearance

Palawan legislators oppose inclusion: ‘We’re not part of Mindanao’ [Philippine Daily Inquirer, January 6, 2026]

In a regular session on Tuesday, January 6, the Palawan SP adopted a resolution “vehemently interposing objection” to the resolution reportedly passed by certain personalities in a gathering in Cagayan de Oro city, seeking Mindanao independence before the United Nations committee on decolonization.

https://newsinfo.inquirer.net/2163780/palawan-legislators-oppose-inclusion-were-not-part-of-mindanao

Sangley airport builder ventures into busway stations [The Philippine Star, January 6, 2026]

The contractor for the previous P486-million development of the Sangley Point Airport has been chosen to design and build the new stations for the EDSA Busway for P251 million.

https://www.philstar.com/business/2026/01/06/2498963/sangley-airport-builder-ventures-busway-stations

PRIVATE RETIREMENT PLAN EXTENDING LOANS TO EMPLOYEES DOES NOT NEED SECONDARY LICENSE UNDER THE LENDING COMPANY REGISTRATION ACT (LCRA]

S. Co., a private retirement plan company, is seeking an opinion on whether it may extend interest-bearing loans exclusively to its eligible and qualified employee-members for housing, education, and other humanitarian purposes without securing a Certificate of Authority to Operate as a Lending Company under the Republic Act (R.A.) No. 9474 or the Lending Company Regulation Act of 2007 (LCRA). In reply, under Section 3(a) of the LCRA, a lending company is one engaged in the regular and commercial business of granting loans to the public for profit using its own capital or funds sourced from not more than 19 persons, and the law was enacted to regulate entities whose core business is lending. Based on the facts supplied, S Co. does not fall within this definition since it is a private retirement plan governed by R.A. No. 4917 or An Act Providing for Tax Exemptions on Early Retirement as newly implemented under Revenue Regulations (RR) No. 15-2025, whose funds are held in trust for the exclusive benefit of employee-members and may not be used for other purposes. The proposed loan program is incidental to S. Co’s primary purpose, confined solely to eligible and qualified employee-members, carried out pursuant to duly registered plan rules, and intended as economic and humanitarian assistance rather than as a profit-oriented activity. Moreover, the lending is neither regular nor public in character and does not involve loanable capital owned by S. Co. and constitutes an exercise of the Company’s implied and incidental corporate powers to advance employee welfare. Thus, considering that retirement plans are already regulated by law and expressly excluded from the coverage of the LCRA, S Co. is not required to obtain a secondary license to implement its proposed loan program. [SEC OFFICE OF THE GENERAL COUNSEL OPINION NO. 25-14, DECEMBER 23, 2025]

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[ASSESSMENTS ISSUED IN CONNECTION WITH THE ISSUANCE OR RENEWAL OF BUSINESS PERMITS, SUCH AS THE TAX ORDERS OF PAYMENT, CANNOT BE DEEMED A NOTICE OF ASSESSMENT CONTEMPLATED UNDER SECTION 195 OF THE LGC OF 1991] [IF THE TAXPAYER RECEIVES AN ASSESSMENT & DOES NOT PAY THE TAX, ITS REMEDY IS TO FILE A WRITTEN PROTEST WITH THE LOCAL TREASURER WITHIN 60 DAYS FROM THE RECEIPT OF THE ASSESSMENT] [NOTICE OF ASSESSMENTS MUST INDICATE THE NATURE OF THE TAX, FEE, OR CHARGE, THE AMOUNT OF DEFICIENCY, THE SURCHARGES, INTERESTS & PENALTIES]

Petitioner Team Energy Corporation filed a Petition for Review seeking to annul the assailed Order, declare the Local Business Tax (LBT) rate for contractors under the Revised Revenue Code of 2017 of the Municipality of Pagbilao as violative of Section 187 of the Local Government Code (LGC) of 1991, as amended, and to obtain a refund of the alleged excess taxes paid pursuant to the disputed rates. The Petitioner contended that the Tax Orders of Payment (TOPs) are merely Billing Statements issued by the LGU for the routine renewal of business permits rather than Notices of Assessment (NOA) under Section 195 of the LGC, thus, Section 196 applies, granting a two-year period from payment of the LBTs to seek a refund, within which both its administrative and judicial claims were timely filed. In addition, the Petitioner asserted its entitlement to a refund of excess LBTs paid, representing the difference between the 60% of 1% rate imposed by the Revised Revenue Code and the 55% of 1% maximum rate allowed under the LGC. Contrarily, the Respondent Municipality of Pagbilao, Quezon, et al., asserted that the Revised Revenue Code remains valid and compliant with the LGC as the proper basis for computing the Petitioner’s LBTs, and that the refund claim was correctly denied for failure to timely appeal the denial of the administrative claim. In ruling, Sections 195 and 196 of the LGC provide distinct remedies for taxpayers, as clarified in the Supreme Court case of City of Manila vs. Cosmos Bottling Corporation. Section 195 addresses protests against assessments issued by local treasurers, while Section 196 covers claims for refunds or tax credits for taxes collected erroneously or illegally. The applicable provision depends on the basis of the LGU’s tax collection. Notably, Section 195 requires that the NOA specify the type of tax, the deficiency amount, and any surcharges, interest, or penalties, as emphasized in Luz R. Yamane vs. BA Lepanto Condominium Corporation. Examination of the TOPs shows that the LBT on contractors did not arise from a tax audit and is not a deficiency tax. The liability is based on the taxpayer’s own gross receipts declarations. Thus, the alleged assessments issued tied to business permit issuance or renewal, like the TOPs, do not qualify as NOA under Section 195. As such, the two-year prescriptive period under Section 196 applies to the Petitioner’s claim for refund or tax credit of improperly collected local taxes. Furthermore, the Petition also challenges the validity of the current rates (60% of 1%) under the Revised Revenue Code of Pagbilao. However, in the case of Mindanao Shopping Destination Corporation, et al. v. Hon. Rodrigo R. Duterte et al., the Supreme Court clarified that Section 191 requires: (i) an existing tax ordinance imposing a tax under the LGC; and (ii) a subsequent ordinance adjusting the tax rate. Premises considered, the case should be REMANDED to RTC for a full trial to determine the Petitioner’s entitlement to a refund. [TEAM ENERGY CORPORATION VS. MUNICIPALITY OF PAGBILAO, QUEZON, ET AL. CTA AC CASE NO. 339, DECEMBER 18, 2025]

MERE PRESENTATION OF THE REGISTRY RECEIPTS, ABSENT ANY AUTHENTICATION OR IDENTIFICATION THAT THE SIGNATURE APPEARING THEREIN IS THE TAXPAYER’S OR HIS OR HER AUTHORIZED REPRESENTATIVE’S, IS INSUFFICIENT TO PROVE ACTUAL RECEIPT BY THE TAXPAYER

Plaintiff-Appellant, People of the Philippines, filed an Appeal seeking to overturn the Regional Trial Court (RTC)’s Decision and Resolution, which acquitted the Accused-Appellee Dexter C. Lao, the President or responsible officer of Bluebasic Marketing Corporation (BMC), of violating Section 255 of the Tax Code and dismissed the civil aspect for deficiency taxes relating to taxable year 2007. Plaintiff-appellant argued that the tax assessment became final and executory because the Accused-Appellee failed to file a protest. It further asserted that it sufficiently proved that the notices were validly served at BMC’s registered address through registered mail and that the Accused-Appellee received them. It averred that all the elements of a violation of Section 255 of the Tax Code, or willful failure to pay tax, were established. In ruling, the Court held that the Assessment Notices were void for violating the Accused-Appellee’s right to due process because the Bureau of Internal Revenue (BIR) failed to prove that these notices were actually received. Although the BIR claimed service by registered mail, it did not formally offer, authenticate, or otherwise prove receipt of the registry receipt or return card, and the Accused categorically denied receiving any notice. Without a valid service, the tax assessment is VOID and produces no legal effect, rendering subsequent collection actions likewise invalid. Consequently, the Prosecution failed to establish the first element of willful failure to pay tax. Further, no civil liability may be imposed despite an acquittal, as the BIR presented no competent evidence proving the existence and amount of the alleged deficiency tax assessments. The use of “Best Evidence Obtainable” was unjustified because the Accused-Appellee was never properly notified. Finally, even assuming tax deficiencies existed, he cannot be held personally liable for corporate tax obligations absent proof of bad faith, fraud, or grounds to pierce the corporate veil. Thus, the Plaintiff-Appellant’s appeal was DENIED for lack of merit. Consequently, the assailed Decision and Resolution were AFFIRMED. [PEOPLE OF THE PHILIPPINES VS. DEXTER C. LAO, CTA CRIMINAL CASE NO. A-22, DECEMBER 17, 2025]