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Philippine Bar review · Question

Practice question: Tax Deficiency vs. Tax Delinquency

Multiple Choice Hard

Practice question

A covered micro taxpayer has a valid final assessed deficiency unpaid after the demand deadline. It argues EOPT interest relief means there can be neither a delinquent tax nor any interest. Which is best?
  1. EOPT automatically pays every micro taxpayer's basic tax.
  2. The rate reduction does not erase the unpaid basic tax or its delinquent status; apply the proper reduced interest without forbidden overlap.
  3. A reduced rate makes all final demands legally nonexistent.
  4. Every covered taxpayer must pay both current deficiency and delinquency interest for identical periods.
  5. Only the taxpayer's annual sales label determines whether payment occurred.

Legal references

  • CIR v. Stradcom Corporation, G.R.255520, April21,2025, MAIN decision: https://lawphil.net/judjuris/juri2025/apr2025/gr_255520_2025.html
  • RA10963, TRAIN, amended NIRC249 deficiency/delinquency interest: https://lawphil.net/statutes/repacts/ra2017/ra_10963_2017.html
  • RA11976, Ease of Paying Taxes Act, reduced interest for micro and small taxpayers: https://lawphil.net/statutes/repacts/ra2024/ra_11976_2024.html

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