ARTICLE
9 July 2026

Tax Updates March 2026 (SyCipLaw Tax Issues And Practical Solutions (T.I.P.S.) International Edition Vol. 14)

SS
SyCip Salazar Hernandez & Gatmaitan

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SyCip Salazar Hernandez & Gatmaitan was founded in 1945 and is a leading full-service law firm in the Philippines. Its principal office is in Makati City, with branch offices in Cebu City, Davao City and the Subic Bay Freeport Zone. The firm offers a broad and integrated range of legal services, with departments in the following fields: banking, finance and securities; special projects; corporate services; litigation and dispute resolution; employment law and immigration; intellectual property; and tax.
SyCipLaw's Tax Department addresses six critical tax questions in its first quarter 2026 bulletin, examining issues from the Solicitor General's entitlement to compromise payments to the implementation of the new Single-Instance Audit Framework. The publication explores complex scenarios involving branch profits remittance taxes, documentary stamp tax on international loan transactions, VAT procedures for ecozone purchases, and the handling of tax liabilities during regulatory transitions.
Philippines Tax
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SyCipLaw’s Tax Department has prepared an international edition of its Tax Issues and Practical Solutions (T.I.P.S.) for the first quarter of 2026.

The SyCipLaw T.I.P.S – International Edition covers the following tax issues:

  1. Is the Office of the Solicitor General entitled to a 5% share of the compromise amount paid by the taxpayer, even if it did not actively participate in the court proceedings?
  2. May the Bureau of Internal Revenue sustain a deficiency branch profits remittance taxes on the ground of unaccounted retained earnings?
  3. Is a loan transaction subject to documentary stamp tax if the proceeds of the loan are proven to be utilized outside the Philippines by the lender’s affiliates?
  4. If goods are purchased from a Registered Business Enterprise located in an ecozone or freeport, how should the local buyer pay VAT, and what documents are required for release of the goods?
  5. What are the material dates during the transition to the Single-Instance Audit Framework pursuant to Revenue Memorandum Order No. 1-2026?
  6. What happens to tax liabilities that were already assessed and paid before a Replacement eLA is issued for the same taxable period during the transition to the Single-Instance Audit Framework?

Please read the full text here or via this link.

This bulletin was prepared with the assistance of Associates Tyrone Matthew L. Dy, Josemaria Alvaro C. Fontillas, and Jarel Simon K. Uy.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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