Summary
RMC No. 48-2011 circularizes excerpts from the En Banc Supreme Court Decision in Commissioner of Internal Revenue vs. Filinvest Development Corporation, GR Nos. 163653 and 167689 dated July 19, 2011, on Documentary Stamp Tax on inter-corporate loans.
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Key points
- Instruction to BIR employees. BIR employees engaged in the audit and review of audit cases are enjoined to assess deficiency DST, if warranted, on transactions involving an inter-office memo covering advances granted by an affiliated corporation.
Who is affected
- BIR employees engaged in audit and review of audit cases
Deadlines and effectivity
- Decision dated July 19, 2011
Summary by Tax Resources PH. It is not a substitute for the full text of the issuance or professional advice.
Copies of BIR issuances are hosted here for reference. For the official version, check bir.gov.ph. Summaries by Tax Resources PH are not a substitute for the full text or professional advice.
