Philippine Bar review · Question

Practice question: Prohibition on Compensation and Set-off

Essay Hard

Practice question

A taxpayer says BIR delay on a disputed refund permits suspension of all current tax payments. Explain the doctrinal response and the role of statutory refund remedies.

Legal references

  • Philex Mining Corporation v. CIR, G.R. No. 125704, August 28, 1998, main decision: https://lawphil.net/judjuris/juri1998/aug1998/gr_125704_1998.html
  • RA 11976, Section 31, amended NIRC Section 204(C): https://lawphil.net/statutes/repacts/ra2024/ra_11976_2024.html

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