Prosper petroleum adminstrative appeal pdf

PROSPER PETROLEUM ADMINSTRATIVE APPEAL PDF FULL

This time, the company opted and marked the box вЂњTo be refundedвЂ™ in respect of the total amount of в‚±1,100,000.00. For taxable year 2016, the companyвЂ™s income tax return showed an overpayment due to excess creditable withholding taxes in the amount of в‚±1,100,000.00, which included the carry-over from year 2015 in the amount of в‚±750,000.00 because its operations resulted in a net loss hence, there was no application for any tax liability. The company opted to carry over the excess income tax credits as tax credit against its quarterly income tax liabilities for the next succeeding years. Vanderful, lnc.вЂ™s income tax return for taxable year 2015 showed an overpayment due to excess creditable withholding taxes in the amount of в‚±750,000.00. If you were the Commissioner of Internal Revenue, will you grant Wreck CorporationвЂ™s administrative claim for refund or issuance of tax credit certificate? Explain your answer. On June 25, 2015, Wreck Corporation filed an administrative claim for refund or issuance of tax credit certificate amounting to the excise taxes it had paid on the importation of 225 million liters of Jet A-1 aviation fuel. Wreck Corporation did not pass on to the international carriers the excise taxes it paid on the importation of petroleum products. Seventy-five percent (75%) of the total volume of aviation fuel imported were actually sold to international carriers of Philippine and foreign registries for their use or consumption outside of the Philippines in the period from Novemto December 31, 2014. During the period from Septemto December 31, 2014, Wreck Corporation imported 225 million liters of Jet A-1 aviation fuel and paid the excise taxes thereon.

Wreck Corporation is a domestic corporation engaged in the business of importing, refining and selling petroleum products. Is the BIR correct in denying SMZ, lnc.вЂ™s application? Explain your answer. However, the BIR denies SMZ, lnc.вЂ™s application on the ground that HP International already enjoys income tax holiday. files an application with the Bureau of Internal Revenue (BIR) for the VAT zero-rating of its sale of services to HP International. HP International is registered with the Philippine Economic Zone Authority (PEZA) as an ecozone export enterprise, and, as such, enjoys income tax holiday pursuant to the Special Economic Zone Act of 1995.

to construct HP lnternationalвЂ™s factory building located in the Laguna Techno Park, a special economic zone. HP International contracts the services of SMZ, Inc. is a VAT-registered enterprise engaged in the general construction business. Marking of your Notebook with your name or other identifying signs or symbols extraneous to the subject matter of the questions may be considered as cheating and may disqualify you.

PROSPER PETROLEUM ADMINSTRATIVE APPEAL PDF FULL

A вЂњYesвЂќ or вЂњNoвЂќ answer sans explanation or discussion will not be given full credit.ДЈ. Answers must fully explain even if the questions do not expressly require explanations. Your answers should demonstrate your ability to analyze the facts, apply the pertinent laws and jurisprudence, and arrive at sound and logical conclusions. Follow the numbering sequence of the Questionnaire in your answers.Дў.

Start every number on a separate page, but an answer to a sub-question under the same number may be written continuously on the same page and on the immediately succeeding pages until the answer is complete. If the front pages are not sufficient, continue at the back of the first page and so on. Write your answers only on the front of every page of your Notebook. Answer the essay questions legibly, clearly, and concisely. Read each question very carefully and write your answers in your Bar Examination Notebook in the same order of the questions. You may write on your Questionnaire as you answer the questions. Check and make sure that your Questionnaire has the correct number of pages. This Questionnaire contains ten (10) pages.

Prosper petroleum adminstrative appeal pdf