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San Miguel Corporation vs. CIR

[G.R. No. 257697] SAN MIGUEL CORPORATION, PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. [G.R. No. 259446] COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. SAN MIGUEL CORPORATION, RESPONDENT.

G.R. No. 257697 | 2023-04-12

D E C I S I O N
 
SINGH, J.:
 
This case prompts the Court to revisit the doctrine laid down in Commissioner of Internal Revenue v. Filinvest (Filinvest),[1] where the Court ruled that instructional letters, as well as journal and cash vouchers evidencing advances made by Filinvest Development Corporation (FDC) to its affiliates, qualified as loan agreements upon which Documentary Stamp Tax (DST) may be imposed.

Before the Court are consolidated Petitions for Review on Certiorari filed by the Commissioner on Internal Revenue (CIR) and San Miguel Corporation (SMC) assailing the Decision,[2] dated September...