Practice question
What feature distinguishes a compromise penalty from a unilaterally imposed statutory civil surcharge?
- It requires a valid compromise agreement rather than unilateral imposition as a suggested settlement
- It is always a judicial sentence
- It automatically cancels all taxes
- It needs no legal authority
- It belongs personally to the revenue officer
Legal references
- RA11976, Section45: https://lawphil.net/statutes/repacts/ra2024/ra_11976_2024.html
- BIR RR6-2024, reduced penalties for micro and small taxpayers: https://bir-cdn.bir.gov.ph/BIR/pdf/RR%206-2024%20(final).pdf
- BIR RMO7-2015, compromise penalty schedule and voluntary settlement rule: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/10/69577
- La Flor Dela Isabela v. CIR, GR202105, April28 2021, main decision: https://lawphil.net/judjuris/juri2021/apr2021/gr_202105_2021.html
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