TAXATION
 
 
Overall Group Head:
Virginia B. Viray

The Taxation Practice Group has extensive experience regarding tax consultancy and structuring for local and foreign investments. The Group also provides advice and services dealing with tax assessments, protests, litigation and appeal on behalf of various enterprises. The Group has had substantial opportunity to work with the Bureau of Internal Revenue (BIR) acting as tax agent to secure rulings and clearances from the BIR, including rulings on tax-free exchange, tax treaty relief and tax accreditation, and clearance for settlement of estate taxes and other transfers of property. Among other services, the Group also handles estate planning for various clients.
Relevant Experience
• Advised various multinational investors on incentives under the Special Purpose Asset Vehicle (SPV) Law. Work included acting as local counsel for a multinational investment company in its successful acquisition non-performing assets estimated atUS$156-Million from a Philippine commercial bank, providing assistance in structuring the transaction, drafting and finalizing transaction documents, coordination with various government agencies for approval, and establishment of a special purpose vehicle under the SPV Act.


• Participated in the negotiations for the acquisition by a Dutch international bank of a Philippine commercial bank. Work involved providing advice to the Philippine party on proper tax structuring and the successful application for rulings approving tax exemptions on transaction related activities.


• Prepared a detailed study of possible tax and cost structuring for a leading transport company listed in the Philippine Stock Exchange.


• Acted as counsel to one of the biggest Philippine real estate developers regarding the successful tax structuring of a PhP6 Billion-real estate transfer transaction with a government corporation.


• With the Litigation Practice Group, provided legal advice and training on alternative dispute resolution (ADR) to lawyers in the Bureau of Internal Revenue (BIR) Head Office.


• Currently provides advice and assistance, including securing applicable rulings and tax-treaty relief to foreign clients investing in the Philippines.