C&G Law advises and acts for a number of conglomerates and multinationals, including companies in the energy, manufacturing, mining, pharmaceutical, transportation, retail and software development sectors, in challenging assessments for various internal revenue taxes and other governmental impositions (such as business, franchise, national wealth, and real property taxes) and claiming tax refunds involving significant sums before various taxation authorities, administrative tribunals, the Court of Tax Appeals and Supreme Court.  C&G Law’s lawyers apply, to prosecution of tax cases handled by the firm, the same competence, diligence, and advocacy with which they litigate civil, commercial, and criminal disputes and arbitration proceedings.

The firm also regularly provides tax advice in non-litigation scenarios.  C&G Law assists clients in determining and implementing efficient tax structures and advises on tax compliance.

Recent work:

• Advising different clients in coming up with the most tax efficient structure for including a joint venture with a local water district for the construction and operation of a bulk water facility.
• Advising an energy generation company on the tax issues involved in the construction and operation of a 300-MW power plant.
• Advising a mass transportation company on the tax issues which may arise from a potential Public-Private Partnership.
• Reviewing monthly and quarterly tax filings and tax compliance of several companies involved in mining and cement production.
• Assisting different clients secure tax treaty relief from the Bureau of Internal Revenue (“BIR”) involving various issues on alienation of shares, residency, royalties, dividends, and permanent establishments.
• Advising a multinational corporation on the propriety of a request from a foreign tax authority to Philippine tax authorities to provide information and documents relating to an investigation on compliance with transfer pricing regulations in a foreign jurisdiction.
• Advising a publicly-listed Japanese company on the tax aspects of its divestment from a joint venture in a company involved in manufacturing of consumer goods.
• Advising a foreign bank and a financial advisory firm on the tax aspects of trusts with offshore assets administered abroad by foreign trustees.
• Advising a client on the tax issues involved in the construction and operation of a beer manufacturing company.
• Advising a client on the tax issues involved in the operation of a hotel business.
• Assisting a manufacturing company apply for a compromise settlement with the BIR involving excise taxes.
• Advising different clients on share and property transfers and assisting them secure certificates authorizing registration from the BIR.
• Assisting clients in the dissolution of their affiliates and assisting them secure tax clearances.
• Assisting power generation companies, a cement production company and a drilling services company secure opinions from the Bureau of Local Government Finance.
• Assisting in the settlement of estate taxes of various individuals.
• Representing a pharmaceutical company in separate proceedings before the BIR involving the assessment of various alleged deficiency taxes (i.e., income tax, value added tax, withholding tax, fringe benefits tax, improperly accumulated earnings tax and documentary stamp tax) in the amount of around P2.1 Billion and P700 Million.
• Representing a mass transportation company in proceedings before the BIR involving the assessment of various alleged deficiency taxes (i.e., income tax, improperly accumulated earnings tax, expanded withholding tax and documentary stamp tax) in the amount of around P18.3 Billion.
• Representing a power generation company in proceedings pending before the BIR involving the assessment of various alleged deficiency income tax of around P420 Million.
• Representing a cement production company in proceedings pending before the BIR involving the assessment of various alleged deficiency income tax of around P250 Million.
• Advising and assisting a logistics company, a financial advisory firm, a sauce manufacturer and a health care company in proceedings before the BIR and courts involving the issuance of subpoenas.
• Representing a mass transportation company in separate proceedings before the Court of Tax Appeals involving the assessment of various alleged deficiency taxes (i.e., income tax, value added tax, expanded withholding tax, final withholding tax, fringe benefits tax and documentary stamp tax) in the amounts of around P1.6 Billion and P9.6 Billion respectively.
• Representing a power generation company located in an export zone in proceedings before the Supreme Court involving the assessment of alleged deficiency taxes as a result of the disallowance various types of expenses purportedly for being indirect costs.
• Representing a power generation company in proceedings before the Central Board of Assessment Appeals questioning the assessment of real property taxes (of around P160 Million annually) where the proper characterization of machinery as anti-pollution devices is the issue.
• Representing a cement manufacturing company in proceedings before a Local Board of Assessment Appeals challenging the assessment of real property taxes where the propriety of depreciation of machinery (valued at around P3 Billion) is the principal issue.
• Representing a power generation company in proceedings pending before a Regional Trial Court contesting an assessment of alleged deficiency business tax of around P350 Million where the proper interpretation of a taxpayer’s gross receipts is involved.
• Representing a telecommunications company in separate proceedings pending before a Regional Trial Court challenging an assessment of alleged deficiency business tax of around P50 Million involving the proper declaration of gross receipts.
• Representing a mall owner in various proceedings in proceedings before different Regional Trial Courts in Bacolod, Cebu, Davao, Iloilo, Mandaue, Manila and Pampanga involving various issues related to alleged deficiency business taxes.
• Representing a mining company in proceedings before different Local Board of Assessment Appeals and Regional Trial Courts which were filed as a result of the overlapping claims of two (2) provinces and three (3) municipalities on the project site.
• Representing a power generation company in various proceedings before a Local Board of Assessment Appeals involving the proper classification of its buildings and machinery.
• Representing power generation companies in different proceedings before the Department of Justice and courts to have municipal revenue ordinances nullified.
• Representing a cement manufacturing company in proceedings before a Regional Trial Court involving the proper allocation of business tax affecting payments to more than twenty (20) local government units.
• Representing a power generation company in proceedings before the Supreme Court involving the proper allocation of business taxes where two (2) municipalities have overlapping claims over the project site.