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Commissioner of Internal Revenue vs. J.P. Morgan Chase Bank

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. J.P. MORGAN CHASE BANK, N.A. – PHILIPPINE CUSTOMER CARE CENTER, RESPONDENT.

G.R. No. 210528 | 2018-11-28

DECISION
 
LEONEN, J.:
 
Respondent's lease of the physical plant space, infrastructure, and other transmission facilities of PeopleSupport (Philippines), Inc., a Philippine Economic Zone Authority (PEZA)-registered Export Enterprise, is not covered within its registered activities. Thus, income derived from it is subject to the regular corporate income tax.

This Petition for Review on Certiorari[1] seeks to reverse and set aside the Court of Tax Appeals En Banc Decision[2]dated July 15, 2013 and Resolution[3] dated December 18, 2013 in CTA EB No. 876. The Court of Tax Appeals En Banc denied the Commissioner of Internal...