Sophia (Sophie) handles tax and energy litigation, dispute resolution, regulatory, and advisory. She has extensively represented clients in the energy, mining, and manufacturing industries, and appeared before local government tribunals, trial and collegiate courts, and quasi-judicial agencies for civil and administrative cases.

Sophie obtained her degree in AB Philosophy from the Ateneo de Manila University in 2009. She graduated from the Ateneo de Manila University School of Law in 2013 where she ranked third in her class and obtained a silver medal for academic excellence. She joined C&G Law in 2013.

Experience

Sophie has extensive experience in advising and assisting clients in Philippine tax laws, rules, and regulations involving the dispute and settlement of questionable or unconscionable tax assessments. She has represented generation companies, multinational manufacturing plants, international pharmaceutical companies, and mass transportation providers before various local government tribunals, trial and collegiate courts, and quasi-judicial agencies.

Sophie also has experience in applications and disputes between power industry participants before the Energy Regulatory Commission (ERC), including applications for approval of Power Supply Agreements (PSAs), Emergency PSAs, applications for authority to develop and own or operate point-to-point transmission facilities, applications for approval of Ancillary Service Procurement Agreements (ASPAs) between generation companies and the grid operator, rate and non-rate disputes between generation companies and distribution utilities or the grid operator.

Tax

• Represented one of the Philippines’ leading generation companies in several actions against a local government unit which is collecting real property taxes on pollution-control devices amounting to around US$2 million per year.
• Assisted in the negotiations and eventual compromise of the generation company’s real property taxes on pollution-control devices, ending the six (6)-year dispute with the local government unit.
• Advocating for the cancellation of assessments by the Bureau of Internal Revenue (BIR) against one of the Philippines’ leading generation companies relating to the coverage of incentives granted to renewable energy developers providing ancillary services to the grid operator.
• Representing multinational pharmaceutical companies in actions against a local government unit assessing and collecting excess business taxes on essential medicines.
• Representing a mass transportation provider in an action against the BIR, which is seeking to collect the aggregate amount of US$32 million in alleged deficiency internal revenue taxes.
• Representing a food manufacturing company in an action against the BIR, which is seeking to collect the aggregate amount of US$9.3 million in alleged deficiency internal revenue taxes.

Energy

• Representing a leading generation company in several concurrent actions before the ERC resulting from the dismissal of almost 20 applications for approval of PSAs which resulted in a supply deficit in the grid.
• Representing a leading generation company in at least ten (10) concurrent applications for the approval of Emergency PSAs with multiple distribution utilities to meet the supply deficit in the grid.
• Representing several renewable energy developers, including the largest wind farm in the Philippines, in their applications for authority to develop and own or operate point-to-point transmission facilities to connect their renewable energy plants to the grid.
• Representing three (3) of the Philippines’ largest renewable energy plants in the applications for approval of their ASPAs with the grid operator.

Memberships

• Member, Integrated Bar of the Philippines (2014-present)