ROYAL DUTCH SHELL HISTORY OF TAX AVOIDANCE
By John Donovan
The oil giant Royal Dutch Shell has a long history as a participant in what the Guardian has aptly described as “the murky world of corporate tax avoidance.”
In February 2009, the Guardian newspaper published an article under the headline: “Offshore – and out of reach to the Revenue“
Extracts
The Anglo-Dutch oil giant Shell, although it is still a British plc operating under UK company law, has shifted its trademarks to Switzerland and its main tax residence to the Netherlands.
Shell, meanwhile, has shifted ownership rights of its iconic scallop-shell roadside sign out of London to a third low-tax regime in Switzerland. It was part of a carefully planned merger of its UK and Dutch arms, which enabled the oil giant to keep many operations from the grip of the British tax authorities. For tax purposes, Royal Dutch Shell plc is now resident in the Netherlands. The company told us that the brand shift to the tax haven canton of Zug was not for tax avoidance, but for “entirely commercial” reasons. “There has been no impact on the Shell brand in the UK,” the company said. It added that there would now be “more effective and consistent management of the Shell trademarks”.
Another article on the same subject was published on the same day by the Guardian under the headline: “TAX GAP“
Extract
Ownership of the iconic scallop sign which appears on thousands of Shell petrol station forecourts has migrated to a Swiss tax haven.
The Anglo-Dutch oil giant which made $50bn (£35bn) in pre-tax profits in 2007, shifted its main tax-residence to the more benign climate of Holland after the merger of its twin UK and Netherlands arms in 2005.
Shell simultaneously moved the ownership of its immensely valuable brands. Legal ownership of the trademarks now belongs to a subsidiary set up in the low-tax canton of Zug, which is entitled to charge royalties for their use to other Shell companies.
The rights were shifted in February 2005 to Shell Brands International AG, a holding company registered in the former Alpine village of Baar, now part of a mini-conurbation joined to Zug itself.
The canton hosts about 18,000 companies, mostly foreign entities set up to take advantage of corporate tax rates as low as 8%, with personal tax for expatriate executives at a similarly enticing level.
This means that, legally speaking, Shell is now simultaneously a British public company, tax-resident in Amsterdam, whose brands are Swiss.
Shell says: “Shell Brands International paid Shell UK Ltd for certain trademarks. This payment was subject to corporation tax on capital gains in the UK. In the future, royalties are payable for the use of the trademark by UK companies”.
In fact, no tax was paid on the sale, because Shell was able to set it against other tax losses.
The Guardian also referred to Shell’s tax avoidance in its subsequent article: “Holding the UK’s major corporations to account“
Extracts
Our innovative online database helped shed light on the murky world of corporate tax avoidance
The series revealed the tax stratagems of many of Britain’s corporate household names. It documented brands shifted offshore by Diageo, Shell, and drug companies AstraZeneca and GlaxoSmithKline.
Royal Dutch Shell was also mentioned in an article published in January 2011 by “This is Money”, under the headline: “Revealed: Tax havens of the top 20 UK companies“
Extract
Shell has 47 offshore subsidiaries, mainly in Bermuda, although the company said that its holding group, Royal Dutch Shell, is based in the Hague and not British tax-resident.
There is nothing new about Shell tax avoidance. The following is an extract from from pages 78 & 79 of the book “Patents for Hitler” by Guenter Reimann published in 1942.
The story of the secret Oil International would not be complete without referring to Liechtenstein, Europe’s mystery state. Liechtenstein, with its capital, Vaduz, is the most remarkable country in war-time Europe. Situated in Central Europe, almost encircled by the Third Reich, it is the only place in the old world where people feel safe, with unprotected frontiers, with only a few policemen maintaining internal order-in short, an idyllic country. How did it escape Hitler’s armies? With a population of only 12,000, it could never have tried to defend its national existence. But we must not forget that the administration of this tiny state offered hospitality to corporations which sought a neutral centre for private empires, free from the struggle of national states and from taxation. This little country in war-torn Europe had been selected by I. G., by Standard Oil, and also by Shell as one of the centres for the super-national world empires. Its only apparent function is to enable private world empires or large corporations to escape from the risks of war and also from taxation.
Solon accuses Shell of smuggling; calls for inquiry
MANILA, Philippines - A congresswoman today accused Pilipinas Shell of "unabated smuggling activities" and tax evasion.
Zambales Rep. Maria Milagros Magsaysay made the accusation as she urged the House of Representatives' committee on ways and means to investigate the oil company.
In the House Resolution 1643, Magsaysay said that the committee should also probe officials of the Bureau of Customs (BOC) and the Bureau of Internal Revenue (BIR) for their alleged failure to "take action and necessary steps to run after Pilipinas Shell."
"The House Committee on Ways and Means should immediately conduct an investigation in aid of legislation to ferret out the truth and determine the culpability of the culprits," said Magsaysay.
According to Magsaysay, Pilipinas Shell started declaring in 2004 its shipments of Catalyctic Cracked Gasoline (CCCG) and Light Catalyctic Cracked Gasoline (LCCG) that arrived at the Port of Batangas as blending components, which the BOC disagreed to. She said that the bureau had found out that the shipments were not blending components, but rather final products and therefore liable for payment of excise taxes and value added taxes on excise taxes.
She said that the oil company contested the BOC findings and got a reprieve from a BIR Memorandum issued by Deputy Commissioner Jose Mario Bunag stating that indeed CCCG and LCCCG are blending components.
The BOC did not agree to the BIR Memorandum, and on Nov. 11, 2009, an eight-member Verification Committee of the BOC found Pilipinas Shell to have committed fraud and was therefore liable to pay taxes in the amount of P7,348,767,933.00.
Magsaysay said that in a separate issuance, acting BIR Commissioner Joel Tan Torres reversed Bunag's position and found that CCCG and LCCG are not blending components and therefore Shell is liable to pay the taxes of P7 billion.
However, the Court of Tax Appeals issued an order enjoining the commissioners of the BOC and the BIR and its agents to refrain collecting taxes from Pilipinas Shell by using as basis the company’s very minimal surety bond, and the interference from then Solicitor-General Alberto Agra and purportedly from Malacañang through "a certain Secretary Favila."
The congresswoman said that despite the very clear case against Shell for smuggling and non-payment of taxes, there is great injustice to the government by the solicitor-generla for its inaction of not pursuing a winning case against Shell at the Court of Tax Appeals.
Magsaysay also alleged that Shell continued its "smuggling activity" from the period July 2010 to April 2011 and imported shipments declared as alkylate, which were found by the BOC at the Port of Batangas as misdeclared.
After subjected to thorough tests and evaluation, a composite team of officials at the Port of Batangas found the alkylate as motor gasoline and therefore subject to the imposition of excise taxes and VAT on excise taxes in the amount of P1,578,269,755.00.
After the findings of misdeclaration and smuggling by Shell of motor gasoline declared to be alkylate, the Collector of the Port of Batangas Juan Tan, immediately sent a memorandum to incumbent BOC Commissioner Angelito Alvarez to demand payment from Shell of the taxes due plus the penalties and interests and surcharges, and to file a criminal case.
Magsaysay said that Alvarez refused to take action, and instead relieved Tan and the other Port of Batangas officials "under questionable and mysterious reasons."
Magsaysay said the government stands to lose several billions of pesos in uncollected taxes, and these indicate that certain government officials may have given undue advantage to smugglers.
"It is imperative for the House to conduct an inquiry on these issues that involved transcendental importance," she said.
MANILA, Philippines - A congresswoman today accused Pilipinas Shell of "unabated smuggling activities" and tax evasion.
Zambales Rep. Maria Milagros Magsaysay made the accusation as she urged the House of Representatives' committee on ways and means to investigate the oil company.
In the House Resolution 1643, Magsaysay said that the committee should also probe officials of the Bureau of Customs (BOC) and the Bureau of Internal Revenue (BIR) for their alleged failure to "take action and necessary steps to run after Pilipinas Shell."
"The House Committee on Ways and Means should immediately conduct an investigation in aid of legislation to ferret out the truth and determine the culpability of the culprits," said Magsaysay.
According to Magsaysay, Pilipinas Shell started declaring in 2004 its shipments of Catalyctic Cracked Gasoline (CCCG) and Light Catalyctic Cracked Gasoline (LCCG) that arrived at the Port of Batangas as blending components, which the BOC disagreed to. She said that the bureau had found out that the shipments were not blending components, but rather final products and therefore liable for payment of excise taxes and value added taxes on excise taxes.
She said that the oil company contested the BOC findings and got a reprieve from a BIR Memorandum issued by Deputy Commissioner Jose Mario Bunag stating that indeed CCCG and LCCCG are blending components.
The BOC did not agree to the BIR Memorandum, and on Nov. 11, 2009, an eight-member Verification Committee of the BOC found Pilipinas Shell to have committed fraud and was therefore liable to pay taxes in the amount of P7,348,767,933.00.
Magsaysay said that in a separate issuance, acting BIR Commissioner Joel Tan Torres reversed Bunag's position and found that CCCG and LCCG are not blending components and therefore Shell is liable to pay the taxes of P7 billion.
However, the Court of Tax Appeals issued an order enjoining the commissioners of the BOC and the BIR and its agents to refrain collecting taxes from Pilipinas Shell by using as basis the company’s very minimal surety bond, and the interference from then Solicitor-General Alberto Agra and purportedly from Malacañang through "a certain Secretary Favila."
The congresswoman said that despite the very clear case against Shell for smuggling and non-payment of taxes, there is great injustice to the government by the solicitor-generla for its inaction of not pursuing a winning case against Shell at the Court of Tax Appeals.
Magsaysay also alleged that Shell continued its "smuggling activity" from the period July 2010 to April 2011 and imported shipments declared as alkylate, which were found by the BOC at the Port of Batangas as misdeclared.
After subjected to thorough tests and evaluation, a composite team of officials at the Port of Batangas found the alkylate as motor gasoline and therefore subject to the imposition of excise taxes and VAT on excise taxes in the amount of P1,578,269,755.00.
After the findings of misdeclaration and smuggling by Shell of motor gasoline declared to be alkylate, the Collector of the Port of Batangas Juan Tan, immediately sent a memorandum to incumbent BOC Commissioner Angelito Alvarez to demand payment from Shell of the taxes due plus the penalties and interests and surcharges, and to file a criminal case.
Magsaysay said that Alvarez refused to take action, and instead relieved Tan and the other Port of Batangas officials "under questionable and mysterious reasons."
Magsaysay said the government stands to lose several billions of pesos in uncollected taxes, and these indicate that certain government officials may have given undue advantage to smugglers.
"It is imperative for the House to conduct an inquiry on these issues that involved transcendental importance," she said.
COMMITTEE NEWS
VOLUME 16 | NO. 41 | 15-APRIL-2009
PROBE:P21B ALLEGED UNPAID EXCISE TAX BY PILIPINAS SHELL
THE COMMITTEE on Ways and Means chaired by Antique Representative Exequiel Javier continued its investigation into the alleged non-payment of excise tax on importations of unleaded gasoline by Pilipinas Shell from May 2004 up to 2008.
In the Committee�s third meeting on the issue, the Bureau of Customs (BOC) maintained that Pilipinas Shell owed the government P21billion in unpaid excise taxes and that the company had been misdeclaring its shipments of unleaded gasoline as catalytically cracked gasoline (CCG) to avoid the taxes.
Tax-exempt
The Bureau of Internal Revenue (BIR) has ruled that imported CCG, an ingredient blended with gasoline to produce unleaded gasoline, is exempt from the excise tax.
Both BOC Commissioner Napoleon Morales and Port of Batangas Customs Collector Juan Tan were of the position that Pilipinas Shell has to pay the tax of P21 billion including penalties for the shipments of unleaded gasoline it brought into the country.
The shipments were released without being taxed on the basis of the Authority to Release Imported Goods (ATRIG) issued by the BIR, according to the two customs officials.
Misdeclaration
In a demand letter, Tan asked Pilipinas Shell to pay the excise tax claiming that the oil company has been importing unleaded gasoline as shown in their invoices, but was declaring it as CCG.
AKBAYAN Party-list Rep. Risa Hontiveros questioned the exemption of CCG from the payment of excise tax, referring to Sec. 129 of the National Internal Revenue Code (NIRC), which provides that excise taxes apply to imported goods.
Likewise, Rep. Reno Lim (3rd District, Albay) said that the issue of misdeclaration of shipments should be looked into.
Responding to these comments, Robert Kanapi of Pilipinas Shell said that CCG is a raw material and not a finished product, and only the latter is subject to excise tax.
�Gasoline products are derived from imported crude oil coming from at least a dozen sources around the world. Crude oil � is mixed with CCG at 30-40 percent ratio in compliance with the Clean Air Act. Imported crude oil is levied a three percent import duty,� Kanapi explained.
BIR ruling
Rep. Andres Salvacion Jr. (3rd District, Leyte) noted that the excise tax used to apply to CCG until a ruling was issued by then BIR Deputy Commissioner Jose Bu�ag exempting it from the excise tax. He contended that the BIR cannot issue a ruling contradicting Section 1508 of the Tariff and Customs Code.
This particular section of the Code authorizes the Customs collector to hold the delivery or release of imported articles whenever the importer has an outstanding and demandable account with the BOC.
�BIR should not favor the importers to the detriment of the government,� Rep. Salvacion stressed.
Tan disclosed that the BIR was under pressure to issue the ruling due to an impending oil shortage at that time. He also said that Pilipinas Shell used to pay one billion pesos annually for CCG imports before the tax exemption was granted.
Smuggling
On Rep. Hontiveros� query on whether the alleged misdeclaration can be considered smuggling, Tan said yes. But he refused to comment on Rep. Hontiveros� inquiry as to whether the BIR colluded with Shell.
Explaining how the BIR arrived at the tax exemption ruling, BIR Director Jethro Sabariaga said the Department of Energy (DOE) was consulted on the matter which confirmed that CCG is a raw material and not a finished product.
BOC Deputy Commissioner Alexander Arevalo apprised the Committee that Commissioner Morales has already formed a task force to study the case and to submit its findings as soon as possible.
However, Rep. Abraham Kahlil Mitra (2nd District, Palawan) observed that the BOC�s creation of a task force was rather a late reaction to the issue. He also bewailed the fact that the Committee hearing is now on its third and yet only a little has been accomplished so far due to �delaying tactics.� He suggested giving the BOC task force a deadline to do its task.
The Chair added that the DOE must be included in the task force and that the latter must be supervised by the Department of Finance (DOF).
The BOC Deputy Commissioner assured Rep. Mitra that the task force findings will be submitted within one week.
DOF�s silence
Noting the silence of the DOF on the controversy, Rep. Nicanor Briones (Party-list, AGAP) asked the department to state its position especially since both the BIR and the BOC are under it.
DOF Undersecretary Estela Sales said the department is still waiting for the position papers of the BIR and BOC even as she took cognizance of the BOC�s creation of a task force to investigate the matter.
The Chair acknowledged the jurisdiction of the BIR over the administration of the excise tax. He cited a portion of Section 246 of the NIRC, which reads that �Any revocation, modification, reversal of any of the rules or circulars ... shall not be given retroactive application if the revocation, modification or reversal will be prejudicial to the tax payers, except in the following cases: where the taxpayer deliberately misstates or omits material facts from his return or any document required of him by the BIR; where the facts subsequently gathered by the BIR are materially different from the facts on which the ruling is based; or where the taxpayer acted in bad faith.�
The Committee is set to schedule another meeting on the matter. BIR Director Sabariaga was also requested to submit the excise tax payments of Pilipinas Shell. Representatives from Petron, Chevron and DOE will also be invited to the succeeding hearings of the Committee.
Source: Committee Administrative Support Service, Committee Affairs Department
VOLUME 16 | NO. 41 | 15-APRIL-2009
PROBE:P21B ALLEGED UNPAID EXCISE TAX BY PILIPINAS SHELL
THE COMMITTEE on Ways and Means chaired by Antique Representative Exequiel Javier continued its investigation into the alleged non-payment of excise tax on importations of unleaded gasoline by Pilipinas Shell from May 2004 up to 2008.
In the Committee�s third meeting on the issue, the Bureau of Customs (BOC) maintained that Pilipinas Shell owed the government P21billion in unpaid excise taxes and that the company had been misdeclaring its shipments of unleaded gasoline as catalytically cracked gasoline (CCG) to avoid the taxes.
Tax-exempt
The Bureau of Internal Revenue (BIR) has ruled that imported CCG, an ingredient blended with gasoline to produce unleaded gasoline, is exempt from the excise tax.
Both BOC Commissioner Napoleon Morales and Port of Batangas Customs Collector Juan Tan were of the position that Pilipinas Shell has to pay the tax of P21 billion including penalties for the shipments of unleaded gasoline it brought into the country.
The shipments were released without being taxed on the basis of the Authority to Release Imported Goods (ATRIG) issued by the BIR, according to the two customs officials.
Misdeclaration
In a demand letter, Tan asked Pilipinas Shell to pay the excise tax claiming that the oil company has been importing unleaded gasoline as shown in their invoices, but was declaring it as CCG.
AKBAYAN Party-list Rep. Risa Hontiveros questioned the exemption of CCG from the payment of excise tax, referring to Sec. 129 of the National Internal Revenue Code (NIRC), which provides that excise taxes apply to imported goods.
Likewise, Rep. Reno Lim (3rd District, Albay) said that the issue of misdeclaration of shipments should be looked into.
Responding to these comments, Robert Kanapi of Pilipinas Shell said that CCG is a raw material and not a finished product, and only the latter is subject to excise tax.
�Gasoline products are derived from imported crude oil coming from at least a dozen sources around the world. Crude oil � is mixed with CCG at 30-40 percent ratio in compliance with the Clean Air Act. Imported crude oil is levied a three percent import duty,� Kanapi explained.
BIR ruling
Rep. Andres Salvacion Jr. (3rd District, Leyte) noted that the excise tax used to apply to CCG until a ruling was issued by then BIR Deputy Commissioner Jose Bu�ag exempting it from the excise tax. He contended that the BIR cannot issue a ruling contradicting Section 1508 of the Tariff and Customs Code.
This particular section of the Code authorizes the Customs collector to hold the delivery or release of imported articles whenever the importer has an outstanding and demandable account with the BOC.
�BIR should not favor the importers to the detriment of the government,� Rep. Salvacion stressed.
Tan disclosed that the BIR was under pressure to issue the ruling due to an impending oil shortage at that time. He also said that Pilipinas Shell used to pay one billion pesos annually for CCG imports before the tax exemption was granted.
Smuggling
On Rep. Hontiveros� query on whether the alleged misdeclaration can be considered smuggling, Tan said yes. But he refused to comment on Rep. Hontiveros� inquiry as to whether the BIR colluded with Shell.
Explaining how the BIR arrived at the tax exemption ruling, BIR Director Jethro Sabariaga said the Department of Energy (DOE) was consulted on the matter which confirmed that CCG is a raw material and not a finished product.
BOC Deputy Commissioner Alexander Arevalo apprised the Committee that Commissioner Morales has already formed a task force to study the case and to submit its findings as soon as possible.
However, Rep. Abraham Kahlil Mitra (2nd District, Palawan) observed that the BOC�s creation of a task force was rather a late reaction to the issue. He also bewailed the fact that the Committee hearing is now on its third and yet only a little has been accomplished so far due to �delaying tactics.� He suggested giving the BOC task force a deadline to do its task.
The Chair added that the DOE must be included in the task force and that the latter must be supervised by the Department of Finance (DOF).
The BOC Deputy Commissioner assured Rep. Mitra that the task force findings will be submitted within one week.
DOF�s silence
Noting the silence of the DOF on the controversy, Rep. Nicanor Briones (Party-list, AGAP) asked the department to state its position especially since both the BIR and the BOC are under it.
DOF Undersecretary Estela Sales said the department is still waiting for the position papers of the BIR and BOC even as she took cognizance of the BOC�s creation of a task force to investigate the matter.
The Chair acknowledged the jurisdiction of the BIR over the administration of the excise tax. He cited a portion of Section 246 of the NIRC, which reads that �Any revocation, modification, reversal of any of the rules or circulars ... shall not be given retroactive application if the revocation, modification or reversal will be prejudicial to the tax payers, except in the following cases: where the taxpayer deliberately misstates or omits material facts from his return or any document required of him by the BIR; where the facts subsequently gathered by the BIR are materially different from the facts on which the ruling is based; or where the taxpayer acted in bad faith.�
The Committee is set to schedule another meeting on the matter. BIR Director Sabariaga was also requested to submit the excise tax payments of Pilipinas Shell. Representatives from Petron, Chevron and DOE will also be invited to the succeeding hearings of the Committee.
In the Committee�s third meeting on the issue, the Bureau of Customs (BOC) maintained that Pilipinas Shell owed the government P21billion in unpaid excise taxes and that the company had been misdeclaring its shipments of unleaded gasoline as catalytically cracked gasoline (CCG) to avoid the taxes.
Tax-exempt
The Bureau of Internal Revenue (BIR) has ruled that imported CCG, an ingredient blended with gasoline to produce unleaded gasoline, is exempt from the excise tax.
Both BOC Commissioner Napoleon Morales and Port of Batangas Customs Collector Juan Tan were of the position that Pilipinas Shell has to pay the tax of P21 billion including penalties for the shipments of unleaded gasoline it brought into the country.
The shipments were released without being taxed on the basis of the Authority to Release Imported Goods (ATRIG) issued by the BIR, according to the two customs officials.
Misdeclaration
In a demand letter, Tan asked Pilipinas Shell to pay the excise tax claiming that the oil company has been importing unleaded gasoline as shown in their invoices, but was declaring it as CCG.
AKBAYAN Party-list Rep. Risa Hontiveros questioned the exemption of CCG from the payment of excise tax, referring to Sec. 129 of the National Internal Revenue Code (NIRC), which provides that excise taxes apply to imported goods.
Likewise, Rep. Reno Lim (3rd District, Albay) said that the issue of misdeclaration of shipments should be looked into.
Responding to these comments, Robert Kanapi of Pilipinas Shell said that CCG is a raw material and not a finished product, and only the latter is subject to excise tax.
�Gasoline products are derived from imported crude oil coming from at least a dozen sources around the world. Crude oil � is mixed with CCG at 30-40 percent ratio in compliance with the Clean Air Act. Imported crude oil is levied a three percent import duty,� Kanapi explained.
BIR ruling
Rep. Andres Salvacion Jr. (3rd District, Leyte) noted that the excise tax used to apply to CCG until a ruling was issued by then BIR Deputy Commissioner Jose Bu�ag exempting it from the excise tax. He contended that the BIR cannot issue a ruling contradicting Section 1508 of the Tariff and Customs Code.
This particular section of the Code authorizes the Customs collector to hold the delivery or release of imported articles whenever the importer has an outstanding and demandable account with the BOC.
�BIR should not favor the importers to the detriment of the government,� Rep. Salvacion stressed.
Tan disclosed that the BIR was under pressure to issue the ruling due to an impending oil shortage at that time. He also said that Pilipinas Shell used to pay one billion pesos annually for CCG imports before the tax exemption was granted.
Smuggling
On Rep. Hontiveros� query on whether the alleged misdeclaration can be considered smuggling, Tan said yes. But he refused to comment on Rep. Hontiveros� inquiry as to whether the BIR colluded with Shell.
Explaining how the BIR arrived at the tax exemption ruling, BIR Director Jethro Sabariaga said the Department of Energy (DOE) was consulted on the matter which confirmed that CCG is a raw material and not a finished product.
BOC Deputy Commissioner Alexander Arevalo apprised the Committee that Commissioner Morales has already formed a task force to study the case and to submit its findings as soon as possible.
However, Rep. Abraham Kahlil Mitra (2nd District, Palawan) observed that the BOC�s creation of a task force was rather a late reaction to the issue. He also bewailed the fact that the Committee hearing is now on its third and yet only a little has been accomplished so far due to �delaying tactics.� He suggested giving the BOC task force a deadline to do its task.
The Chair added that the DOE must be included in the task force and that the latter must be supervised by the Department of Finance (DOF).
The BOC Deputy Commissioner assured Rep. Mitra that the task force findings will be submitted within one week.
DOF�s silence
Noting the silence of the DOF on the controversy, Rep. Nicanor Briones (Party-list, AGAP) asked the department to state its position especially since both the BIR and the BOC are under it.
DOF Undersecretary Estela Sales said the department is still waiting for the position papers of the BIR and BOC even as she took cognizance of the BOC�s creation of a task force to investigate the matter.
The Chair acknowledged the jurisdiction of the BIR over the administration of the excise tax. He cited a portion of Section 246 of the NIRC, which reads that �Any revocation, modification, reversal of any of the rules or circulars ... shall not be given retroactive application if the revocation, modification or reversal will be prejudicial to the tax payers, except in the following cases: where the taxpayer deliberately misstates or omits material facts from his return or any document required of him by the BIR; where the facts subsequently gathered by the BIR are materially different from the facts on which the ruling is based; or where the taxpayer acted in bad faith.�
The Committee is set to schedule another meeting on the matter. BIR Director Sabariaga was also requested to submit the excise tax payments of Pilipinas Shell. Representatives from Petron, Chevron and DOE will also be invited to the succeeding hearings of the Committee.
Source: Committee Administrative Support Service, Committee Affairs Department
The TRUTH will set you FREE.
