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Commissioner of Internal Revenue vs. Phoenix Assurance Co., Ltd.121 Phil. 832

THE COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. PHOENIX ASSURANCE CO., LTD., respondent.

G.R. No. L-19727 | 1965-05-20

D E C I S I O N



BENGZON, J.P., J.:


From a judgment of the Court of Tax Appeals in C. T. A. Cases Nos. 305 and 543, consolidated and jointly heard therein, these two appeals were taken. Since they involve the same facts and interrelated issues, the appeals are herein decided together.

Phoenix Assurance Co., Ltd., a foreign insurance corporation organized under the laws of Great Britain, is licensed to do business in the Philippines with head office in London. Through its head office it entered, in London, into worldwide reinsurance treaties with various foreign insurance companies. It agreed to cede a portion of premiums received on original...