Practice question
A city taxes a manufacturer under its specific manufacturer-business-tax provision. It then imposes another local business tax under a residual provision applicable only to businesses not otherwise specified. Both charges cover the same business privilege, purpose, city, year and kind of gross-receipts tax. Following City of Manila v. Coca-Cola, which conclusion is strongest?
- The residual tax cannot be added in disregard of its scope; the stated features also establish direct duplication
- The city may always collect both merely by assigning separate section numbers
- The second tax is valid because gross receipts are never relevant
- A manufacturer is necessarily outside all local taxing power
- A residual provision invariably overrides a specific category
Legal references
- City of Manila v. Coca-Cola Bottlers Philippines, G.R. 181845, August 4, 2009: https://lawphil.net/judjuris/juri2009/aug2009/gr_181845_2009.html
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