Practice question
Distinguish a discretionary compromise under NIRC Section 204 from a statutory tax amnesty. Use CIR v. Transfield's treatment of full compliance with RA 9480, without assuming that the historical amnesty remains open today.
Legal references
- NIRC, Section 204(A); https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
- CIR v. Transfield Philippines, Inc., G.R. 211449, January 16, 2019 (main decision), RA 9480 amnesty; https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/65000
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