Tax
Lauded for its excellent expertise and ability to "zero in on just what it is the client wants to achieve", C&G Law’s tax practice is top-notch.
C&G Law regularly advises and acts for several leading Philippine conglomerates and MNCs in challenging assessments for various internal revenue taxes and other governmental impositions, and claiming tax refunds involving significant sums before various tax authorities, administrative tribunals, the Court of Tax Appeals, and the Supreme Court.
C&G Law’s Tax Practice also regularly advises several leading Philippine conglomerates and MNCs on corporate and commercial transactions and other non-litigious matters, such as in determining and implementing efficient tax structures in high value mergers and acquisitions, as well as in large-scale projects, infrastructure, and energy matters.
The Practice advises clients from a variety of industries, including agriculture, beverage, business process outsourcing, education, energy, food production, manufacturing, mining, pharmaceutical, telecommunications equipment, transportation, retail, and software development sectors.
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.
Related Links
Recognition
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Tier 1 – TaxThe Legal 500 Asia-Pacific (2025)
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Recommended – Taxasialaw Profiles (2024)
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Ranked – TaxChambers Asia-Pacific (2025)
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Ranked – Dispute Resolution: TaxBenchmark Litigation Asia Pacific (2023)
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"Gatmaytan Yap Patacsil Gutierrez & Protacio are able to provide detailed information, and importantly able to explain to people from legal and non-legal backgrounds. The guidance given is always insightful."Chambers Asia-Pacific (2024)
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"Gatmaytan Yap Patacsil Gutierrez & Protacio continues to be prominent in tax disputes in the Philippines, with notable experience in challenging tax assessments."Chambers Asia-Pacific (2022)
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"C&G Law has top-notch tax lawyers with comparable exceptional academic and professional backgrounds. It also has an international linkage... which we find very useful especially for issues involving cross-border transactions as well as transfer pricing."The Legal 500 Asia-Pacific (2024)
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"A technically strong team that provides practical advice with due consideration for commercial realities. Responsive and supportive."The Legal 500 Asia-Pacific (2024)
A technically strong team that provides practical advice with due consideration for commercial realities. Responsive and supportive."
Our Tax Team
