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National Internal Revenue Code of 1997 5th Edition
It is common for taxpayers dealing with foreign entities, whether for purchases or sales, to have transactions in foreign currency. Therefore, it is important for taxpayers to be guided by the rules governing the use of forex rates in business transactions.
The Supreme Court, through its decision in Aces Philippines Cellular Satellite Corp. (Aces Philippines) vs. Commissioner of Internal Revenue (G.R. No. 226680, August 30, 2022), ruled that the airtime fees Aces Philippines paid to its related party, Aces Bermuda, under an airtime purchase agreement are considered sourced from the Philippines and are therefore subject to withholding tax.
The most successful organizational executives have an unquenchable drive for expansion, even in a challenging economic climate. Businesses must have the hunger for growth by making the appropriate decisions on supply chain management, technology, market research, integration, and human resources. And in the dynamic landscape of commerce, exploring the longevity of a business is akin to embarking on a captivating journey through time.
For years, taxpayers have been wishfully thinking of simple and practical yet comprehensive tax laws and regulations for better compliance. With this, our legislators heeded the call, embraced the convenience brought about by digitalization, and introduced changes adapting to the current taxpayer’s situation.
With differences in financial reporting under Philippine Financial Reporting Standards (PFRS)/Philippine Accounting Standards (PAS) and tax treatment purposes under the National Internal Revenue Code (NIRC) that arise due to the forex rates applied in foreign currency transactions, BIR recently issued RMC No. 12-2024 which aims to clarify the treatment of foreign currency transactions for financial reporting and internal revenue tax purposes, as well as define and specify the rules for recording and disclosing foreign exchange transactions for tax purposes, including the use of appropriate foreign exchange rates.
Is there a flow of wealth when there is a reimbursement at cost? Is there an income to speak of when repaying a cost allocated by a related party?
In its recently issued Revenue Regulation (RR) No. 1-2024, the Bureau of Internal Revenue (BIR) increased the selling price threshold for VAT exemption purposes of the sale of house and lot, and other residential dwellings, further amending Section 2, Sub-section 4.109-1(B)(p) of Revenue Regulations No. 4-2021.
Terrorism needs funding. Preventing and disrupting the financing of terrorism is key to limiting the capability of terrorist groups to prepare or carry out attacks. In the recent twin blasts that killed at least 84 people and wounded more than 280 people in Iran, the ISIS armed group claimed responsibility. It was the deadliest attack to target Iran since its 1979 Islamic revolution.