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CTA partially grants P29-M tax credit to Global Energy Supply Corp.

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September 24, 2024
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CTA.JUDICIARY.GOV.PH

THE COURT of Tax Appeals (CTA) has granted Global Energy Supply Corp. a P29-million tax credit for unutilized creditable withholding taxes (CWT) in 2019, partially approving the company’s request.

In a Sept. 20 decision, the CTA Third Division ruled that the company, a licensed retail electricity supplier, is entitled to a P29-million tax return out of the P32 million petitioned, due to insufficient documentation of its 2019 taxable income.

“The petitioner has sufficiently proven that it is entitled to the issuance of tax credit certificate in the amount of P29,074,538 representing its unutilized CWTs for 2019, pursuant to Section 76 in relation to Sections 204 and 229 of the Tax Code,” a part of the 22-page ruling of Associate Justice Henry S. Angeles read.

“Only the amount of P29,074,538 CWT must be granted, considering that this is the amount which corresponds to the income payments which were verified to have been included in petitioner’s taxable gross income per its annual ITR (income tax return) for TY (Taxable Year) 2019,” it added.

The decision noted that upon reviewing the petitioner’s 2019 general ledger, which showed total revenues of P1,596,114,046, it was found that these figures matched the revenues reported in the petitioner’s 2019 audited financial statements and annual income tax return. However, the income associated with the claimed CWT was only P1,588,350,922. — Kenneth Christiane L. Basilio

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