Manila: The Court of Tax Appeals has affirmed its earlier ruling in favor of the Panay Power Corporation's claim for a refund of PHP15 million in unutilized and excess withholding tax for 2019. On June 1, 2020, Panay Power filed its annual income tax return (AITR) for the year 2019, which reflected an overpayment of some PHP26.25 million. On February 22, 2022, the company filed a petition before the Bureau of Internal Revenue (BIR) requesting a PHP16,279,531.00 refund. Subsequently, Panay Power filed a petition for review before the CTA on May 30, 2022.

According to Philippines News Agency, during the trial, the BIR contended that Panay Power was not entitled to the claim for a refund of creditable withholding tax (CWT). The BIR argued that the company did not provide supporting documents to show that the income from which the CWT was being claimed was declared in the AITR. Furthermore, the BIR claimed that Panay Power failed to comply with the prescribed checklist of requirements for claims involving unutilized CWT as outlined in Revenue Memorandum Order No. 53-98 and did not prove compliance with Revenue Regulations No. 2-2006. The BIR also stated that Panay Power failed to present evidence to prove the actual remittance of the alleged taxes to the BIR.

The CTA, however, rejected the respondent's arguments. In its decision dated April 15, 2025, the CTA stated that Panay Power 'sufficiently proved that it is entitled to a refund or issuance of tax credit certificate in the amount of PHP14,997,644.'