Under the law, are satellite airtime fees paid to a non-resident foreign corporation considered income from within the Philippines, and therefore subject to final withholding tax? If so, is the local payor liable for deficiency withholding tax and delinquency interest?
Listen to the #SupremeCourtPH Podcast with guest Court of Tax Appeals Associate Justice Lanee S. Cui-David. A certified public accountant, Justice Cui-David is a member of the Taxation Law Department of the Philippine Judicial Academy. She previously served as Deputy Commissioner of the Bureau of Internal Revenue and headed the Bureau’s Information Systems Group.
Supreme Court Chief Communications Officer Atty. Mike Navallo and Justice Cui-David discuss income tax from satellite transmissions within the context of the case of Aces Philippines Cellular Satellite Corporation v. The Commissioner of Internal Revenue, GR No. 226680. This decision was penned by Associate Justice Henri Jean Paul B. Inting and decided by the Supreme Court En Banc on August 30, 2022.