CTA upholds partial Petron excise tax refunds in twin rulings

THE Court of Tax Appeals (CTA) En Banc upheld two First Division rulings granting Petron Corp. partial refunds of excise taxes on petroleum products sold to tax-exempt entities, denying separate appeals filed by the oil company and the Commissioner of Internal Revenue (CIR), according to two decisions published by BusinessWorld on July 10.

Both decisions, promulgated on July 2, involve claims for refund or credit of excise taxes paid on petroleum products sold to entities exempt from such taxes, such as those engaged in international shipping or operating under special laws. The CTA En Banc affirmed the First Division’s findings that Petron was entitled to partial refunds but not the full amount claimed, ruling that the oil company had sufficiently proven only part of its sales to qualified tax-exempt buyers.

The twin rulings highlight ongoing tax disputes in the Philippine oil industry over excise tax treatment of sales to exempt entities, with the CTA serving as the final appellate authority on tax assessments and refunds. Petron and the CIR have not publicly commented on whether they will pursue further legal remedies.