Practice question
During the RA 9480 amnesty period, a qualified taxpayer fully complied with the law's documentary and payment requirements for a covered liability. The BIR nevertheless seeks collection solely on an exclusion added by an administrative circular rather than the statute. Under CIR v. Transfield, which response is correct?
- The BIR cannot defeat the statutory amnesty by adding an unauthorized exclusion after full compliance.
- The BIR may always add exclusions even if inconsistent with the statute.
- Every amnesty is merely an unaccepted compromise offer.
- Compliance is irrelevant until Congress individually approves the taxpayer.
- The case establishes that every tax in every later year is forgiven.
Legal references
- 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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