NextGen Day

Toyota Motor Philippines Corp. has received a tax refund of PHP144.13 million, according to a decision upheld by the Court of Tax Appeals (CTA) en banc.

The tax court declined the Bureau of Customs’ request for reconsideration of a prior decision made by the CTA’s First Division in January 2021 in its decision from November 4 that was posted online on Wednesday.

The company claimed that because Executive Order 905, which implements the Japan Philippines Economic Partnership Agreement (JPEPA), the applicable duty rate on motor vehicles with cylinder capacities above 3,000cc is zero percent, it is entitled to a refund for overpaid VAT and excise taxes on imports.

The Bureau of Customs (BOC) was directed by the First Division decision of the tax court from January of last year to “refund or issue a tax credit certificate in favor of Toyota Motor Philippines Corp. the amount of PHP144.13 million.”

From January 1 to June 30, 2010, the company imported completely built-up (CBU) motor vehicles with cylinder capacities of over 3,000 cc and knock-down components, parts, and accessories for the assembly of motor vehicles from Japan. The sum represents excess customs duties, excise taxes, and value-added taxes paid on those imports.

The dispute occurred when regional BOC offices decided to reject Import Entry and Internal Revenue Declarations (IEIRDs) and/or Single Administrative Documents (SADs) that had not been machine validated, alleging that the corporation had not used all administrative remedies.

According to Toyota, the practice was against the administrative rules in effect at the time of its importation of goods.

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