Philippines Court of Tax Appeals Issues Decision Clarifying Entitlement to Refunds of Documentary Stamp Tax

Oct. 7, 2025, 5:00 AM UTC

The Philippine Court of Tax Appeals Sept. 24 issued a decision in CTA Case No. 11147, clarifying entitlement to refunds of documentary stamp tax (DST). The taxpayer, the Central Bank, sought a refund of the DST paid on the acquisition of foreclosed properties from a construction company. The Commissioner of Internal Revenue denied the claim, arguing the payment was made due to a natural obligation. On appeal, the Court of Tax Appeals, First Division, found that: 1) the transaction fell under a DST exemption for the Central Bank under the National Internal Revenue Code 1997; 2) the taxpayer’s payment didn’t ...

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