CASE DIGEST: Commissioner of Internal Revenue vs. Shinko Electric Industries Co., Ltd.

 


Commissioner of Internal Revenue Vs. Shinko Electric Industries Co., Ltd.
G.R. No. 226287. July 6, 2021

FACTS:

Respondent Shinko is a  Philippine-registered representative office of the foreign corporation Shinko Electric Industries Co., Ltd., a company organized and existing under the laws of Japan. It is licensed in the Philippines as a  representative office to "undertake activities such as but not limited to information dissemination, promotion of the parent company's products, quality control of products as well as all other activities which may be legally undertaken by a representative office.

On October 16, 2009, Shinko received a Letter of Authority for the examination of its books of accounts and other accounting records for all internal revenue taxes for the period from April 1, 2006 to March 31, 2007.

On April 12,2010, Shinko received a Preliminary Assessment Notice (PAN) together with the Details of Discrepancies from the CIR for alleged deficiency income tax and VAT covering the fiscal year ending March 31, 2007. Thereafter, Shinko filed its reply to the PAN.

On May 14, 2010, Shinko received from the CIR a Formal Assessment Notice with Details of Discrepancies.

Shinko duly protested the FAN and the Assessment Notices. Shinko argued that it is a representative office of a foreign corporation, and, as such, it does not derive income from sources within the Philippines. Hence, it is not liable for deficiency income tax and VAT, as well as the compromise penalty.

On the other hand, the CIR claimed that since Shinko is engaged in the "promotion of the parent company's product", it should be taxed as a Regional Operating Headquarter which derives income from the Philippines.

ISSUE:

Whether or not Shinko should be taxed

RULING:

The term "representative office" is not explicitly defined under the NIRC, as amended. However, a definition thereof can be found in Section l(c), Rule I of the IRR of RA No. 7042, as amended, which states:

x x x Representative or liaison office deals directly with the clients of the parent company but does not derive income from the host country and is  fully subsidized by its head office. It undertakes activities such as but not limited to information dissemination and promotion of the company's products as well as quality control of products.

It can be gleaned from the foregoing that a representative office has the following characteristics:

a.) It is fully subsidized by its head office;

b) It deals directly with the clients of its parent company;

c) It undertakes activities such as but not limited to information dissemination, promotion of the parent company's products as well as quality control of products; and

d) It does not derive income in the Philippines.

On the other hand, an RHQ is an office principally intended to render administrative services. It is not allowed under the law to participate in any manner in the management of any subsidiary or branch office it might have in the Philippines or to solicit or market goods and services whether on behalf of its mother company or its branches, affiliates, subsidiaries or any other company. RHQ's activities are limited to acting as supervisory, communications and coordinating center for its affiliates, subsidiaries or branch offices in the region. In performing such activities, an RHQ does not earn or derive income in the Philippines. Consequently, the NIRC exempts RHQs from income tax and VAT.

In stark contrast to an RHQ, an ROHQ is allowed by law to perform activities that generate income in the Philippines. These activities, termed as "qualifying services", include the following: (1) general administration and planning; (2) business planning and coordination; (3) sourcing/procurement of raw materials and components; (4) corporate finance advisory services; (5) marketing control and sales promotion; ( 6) training and personnel management; (7) logistics services; (8) research and development services, and product development; (9) technical support and maintenance; (10) data processing and communication;  and (11) business development. However, similar to an RHQ, an ROHQ performs services only with the head office's affiliates, branches or subsidiaries. ROHQs are also prohibited by law to directly or indirectly market the goods and services of their mother company and its affiliates.

As regards taxes, inasmuch as an ROHQ is primarily engaged in activities that generate income in the Philippines, it is considered a  taxable entity under the NIRC, as amended, and is subject to 10% corporate income tax and 12% VAT.

In sum, the following are the similarities and differences among a representative office, an RHQ, and an ROHQ:

1. A representative office and an RHQ are not allowed to engage in any income-generating activities in the Philippines. An ROHQ, on the other hand, provides qualifying services that generate income in the Philippines.

2. Both a  representative office and an RHQ do not earn or derive income in the Philippines. An ROHQ is allowed to derive income in the Philippines.

3. Unlike an RHQ and an ROHQ, a representative office deals directly with the parent company's clients and not with the affiliates, branches, or subsidiaries.

4. Under the NIRC, as amended, RHQs are exempt from both income tax and VAT so long as they do not render any of the qualifying services, whereas ROHQs shall be subject to a tax rate of 10% of their taxable income from its qualifying services and 12% VAT.

The Court agrees with the CTA that a representative office, while not defined under the NIRC, is akin to an RHQ.

The Court found that Shinko is a representative office.

The amounts subject of the assessment are not considered income and thus, cannot be subject to income tax and VAT.

Income is "defined as an amount of money coming to a person or corporation within a  specified time, whether as payment for services, interest or profit from investment. Unless otherwise specified, it means cash or its equivalent. It can also be thought of as a flow of the fruits of one's labor.

Further, in defining income, the Court in case of Madrigal and Paterno v. Rafferty and Concepcion differentiated it from capital and said that "[t]he essential difference between capital and income is that capital is a  fund; income is a  flow. A fund of property existing at an instant of time is called capital. A flow of services rendered by that capital by the payment of money from it or any other benefit rendered by a fund of capital in relation to such fund through a period of time is called income. Capital is wealth, while income is the service of wealth." Thus, an income tax is  arbitrary and confiscatory if it taxes capital because capital is  not income. In other words, it is income, not capital, which is subject to income tax.

Likewise, case law instructs that for income to be taxable, the following requisites must exist: (1) there must be gain; (2) the gain must be realized or received; and (3) the gain must not be excluded by law or treaty from taxation.

In the case of Shinko, the amounts considered by the CIR as Shinko' s income actually came from the subsidies remitted by its head office abroad, for Shinko's operations in the Philippines. Certainly, these remittances cannot be considered as income because they are not payment for the services rendered by Shinko. They cannot be regarded as a gain realized by Shinko or a flow of fruits from Shinko's labor. At the very least, the remittances Shinko received as subsidy from its parent company can only be regarded as capital which is intended for the continued operation of a representative office in the Philippines, and from which no income tax may be collected or imposed.


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