Title
Commissioner of Internal Revenue vs. Solidbank Corp.
Case
G.R. No. 148191
Decision Date
Nov 25, 2003
The Supreme Court ruled that the 20% final withholding tax on a bank's interest income should be included in the computation of the taxable gross receipts for the gross receipts tax, rejecting the argument that it should not be included.
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Case Digest (G.R. No. 148191)

Facts:

  • Case: Commissioner of Internal Revenue v. Solidbank Corporation (G.R. No. 148191)
  • Date Decided: November 25, 2003
  • Parties:
    • Petitioner: Commissioner of Internal Revenue, represented by Pablo M. Bastes Jr. and Rhodora J. Corcuera-Menzon
    • Respondent: Solidbank Corporation, represented by Esquivas Cruz Conlu & Yabut
  • Main Dispute: Tax treatment of a bank's interest income subject to a 20% final withholding tax (FWT) and its inclusion in the computation of the 5% gross receipts tax (GRT).
  • Key Details:
    • For the calendar year 1995, Solidbank filed Quarterly Percentage Tax Returns showing gross receipts of P1,474,691,693.44 and GRT payments of P73,734,584.60.
    • Solidbank claimed P350,807,875.15 of these gross receipts were from passive income already subjected to the 20% FWT.
    • On June 19, 1997, Solidbank requested a refund or tax credit certificate for the alleged overpaid GRT amounting to P3,508,078.75.
  • Lower Courts:
    • The Court of Tax Appeals (CTA) ruled in favor of Solidbank, ordering a refund of P1,555,749.65.
    • The Court of Appeals (CA) affirmed the CTA's decision.

Issue:

  • (Unlock)

Ruling:

  • Supreme Court Decision: The Supreme Court ruled in favor of the Commissioner of Internal Revenue, reversing and setting aside the decision and resolution of the Court of Appeals.
  • Holding: The 20% FWT on a bank'...(Unlock)

Ratio:

  • Basis of Decision: Interpretation of the Tax Code and relevant revenue regulations.
  • Key Points:
    • The 5% GRT is imposed on the gross receipts of banks, including interest income subject to the 20% FWT.
    • The FWT and the GRT are distinct taxes: the FWT is an income tax on passive income, while the GRT is a percentage tax on business receipts.
    • Interest income, although not actually received by the bank due to withholding, is constructively rece...continue reading

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