Tax

C&G Law advises and acts for a number of conglomerates and multinationals, including companies in the energy and mining sectors, in challenging assessments for various taxes and other governmental impositions (such as business, franchise, national wealth, and real property taxes) and claiming tax refunds involving significant sums before various taxation authorities, administrative tribunals, and the Court of Tax Appeals and other courts. C&G Law's lawyers apply, to prosecution of tax cases handled by the firm, the same competence, diligence, and advocacy with which they litigate civil, commercial, and criminal disputes and arbitration proceedings.

The firm also provides tax advice in non-litigation scenarios. C&G Law assists clients in determining and implementing efficient tax structures and advises on tax compliance.

Recent work:

  • Advised various clients in coming up with the most tax efficient structure, including a joint venture with a local water district for the construction and operation of a bulk water facility.
  • Advised an energy generation company on the tax issues involved in the construction and operation of a 300-MW power plant.
  • Advised a mass transportation company on the tax issues which may arise from a potential public-private partnership.
  • Reviewed monthly and quarterly tax filings and tax compliance of several companies involved in mining and cement production.
  • Assisted in securing tax treaty relief from the Bureau of Internal Revenue (BIR) involving various issues such as the alienation of shares, residency, royalties, dividends, and permanent establishments.
  • Advising a publicly-listed Japanese company on the tax aspects of its divestment from a joint venture in a company involved in manufacturing of consumer goods.
  • Advising a foreign bank on the tax aspects of trusts with offshore assets administered abroad by foreign trustees.
  • Assisting clients on share and property transfers and helps them secure certificates authorising registration from the BIR.
  • Assisting in the settlement of the estate of various individuals.
  • Representing a pharmaceutical company in proceedings before the BIR involving the assessment of various alleged deficiency taxes (i.e., income tax, value added tax, withholding tax, fringe benefits tax, improperly accumulated earnings tax and documentary stamp tax) in the amount of around P2.1 Billion.
  • Representing a mass transportation company in proceedings before the BIR involving the assessment of various alleged deficiency taxes (i.e., income tax, improperly accumulated earnings tax, expanded withholding tax and documentary stamp tax) in the amount of around P7.6 Billion.
  • Representing a power generation company in proceedings pending before the BIR involving the assessment of various alleged deficiency income tax of around P420 Million.
  • Representing a cement production company in proceedings pending before the BIR involving the assessment of various alleged deficiency income tax of around P250 Million.
  • Representing a power generation company located in an export zone in proceedings before the Supreme Court involving the assessment of alleged deficiency taxes as a result of the disallowance various types of expenses purportedly for being indirect costs.
  • Representing a cement manufacturing company in proceedings before a Local Board of Assessment Appeals challenging the assessment of real property taxes where the propriety of depreciation of machinery (valued at around P3 Billion) is the principal issue.