Practice question
A valid statute changes the tax treatment of future transactions. A taxpayer cites an earlier BIR interpretation and argues that Section246 alone freezes the law for all future transactions, even though no prejudicial retroactive ruling change is imposed on past acts. Which answer is correct?
- Section246 is not a universal permanent exemption from prospective legislation; its stated rule concerns prejudicial retroactivity of the specified ruling changes
- Every BIR interpretation permanently prevents later legislation
- Section246 abolishes all legislative power to change a tax
- The taxpayer may disregard the new law solely by keeping a copy of the old ruling
- The provision expressly guarantees every historical rate forever
Legal references
- NIRC under RA8424, relevant unchanged provisions: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html Section246.
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