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RMC No. 70-2007: Clarifies the proper treatment of cases under administrative or judicial protest for amnesty tax purposes

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Summary

RMC No. 70-2007 clarifies how cases under administrative or judicial protest are treated for amnesty tax purposes.

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Key points

  1. Cases outside the amnesty. Protested cases that involve issues the courts previously decided with finality are no longer covered by the amnesty law, because the Supreme Court has already ruled on those issues with finality and applied the ruling to other cases in similar circumstances.
  2. Basis. Article 6, Section 28 of the Philippine Constitution states that the rule of taxation shall be uniform and equitable. Persons, properties and events similarly situated should be treated alike, so the final resolution applied in at least one instance is applied to all similar instances.

Who is affected

  • Taxpayers with cases under administrative or judicial protest on issues already decided with finality

Summary by Tax Resources PH. It is not a substitute for the full text of the issuance or professional advice.

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