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CTA: Ayala Corp. eligible for P308-M tax credit certificate

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THE Court of Tax Appeals (CTA) has partially granted Ayala Corp. a tax credit certificate worth more than P308 million, covering excess and unused creditable withholding taxes (CWT) for 2018 and 2019.

In a decision publicized on June 19, the CTA Third Division ruled that Ayala Corp. had sufficiently demonstrated its entitlement to the tax credit certificate.

The amount represents the excess and unutilized CWT for the specified years.

“Accordingly, the Commissioner of Internal Revenue is ordered to issue a tax credit certificate in favor of petitioner Ayala Corp. in the reduced amount of P308,235,301.61, representing excess and unutilized creditable withholding taxes for the calendar years 2018 and 2019,” a part of the 20-page ruling of Justice Marian Ivy F. Reyes-Fajardo read.

Ayala Corp. argued for the approval of its CWT claim based on several grounds. Firstly, it filed both administrative and judicial claims within the prescribed two-year period. Additionally, it substantiated its excess and unutilized CWT amounts with Certificates of Creditable Tax Withheld at Source.

Further, Ayala Corp. said it ensured that the income subject to CWT was accurately included as part of its gross income in the amended Annual Income Tax Returns for both 2018 and 2019.

Ayala Corp. also said it did not exercise the option to carry over its excess and unutilized CWTs to following years.

The respondent countered that the corporation is not entitled to claim issuance of the tax credit certificate for its excess and unutilized CWTs over the two-year period due to its failure to submit complete supporting documents. — Chloe Mari A. Hufana

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