THE Court of Tax Appeals has directed the Bureau of Internal Revenue to return P127.67 million in tax refund to the government of Singapore.
Under Section 32(B)(7)(a) of the National Internal Revenue Code, the tax court invoked GIC Private Ltd., a wholly owned by the Singaporean government, was tax-exempt.
Associate Justice Ma. Belen Ringpis-Liban of the Third Division issued the decision, which was concurred by Associate Justices Lovell Bautista and Esperanza Fabon-Victorino.
The P127.67-million tax refund represented the interest income earned from the treasury bond investments of the wealth fund of the Singaporean government.
A 20-percent final withholding tax from the interest income on treasury bonds must be collected and remitted by the Bureau of Treasury to the BIR.
The BIR collected taxes from the GIC Private Ltd. in January 2013 to July 2014
The law exempts foreign governments and their financing institutions from such taxes.
The Court of Tax Appeals gave credence to the certificate issued by the Singaporean Ministry of Finance as authenticated by Philippine Consul in Singapore J. Anthony Reyes affirming the company was owned by the government.