4. Donor’s Tax

Donor's Tax

The supplied primary sources contain no statutory rules or judicial doctrines governing Donor's Tax, as the decisions pertain instead to value-added tax and corporate income tax.¹²

In Tayam v. Recto, G.R. No. 280898, 22 April 2026, the Supreme Court ruled on procedural standing and value-added tax principles, underscoring that locus standi may be relaxed when serious constitutional issues of transcendental importance are raised.¹ Furthermore, under the destination principle governing the value-added tax as a consumption tax, goods and services are subject to tax exclusively in the country where they are consumed.¹

In Association of International Shipping Lines, Inc. v. Secretary of Finance and Commissioner of Internal Revenue, G.R. No. 222239, 15 January 2020, the Court held that Gross Philippine Billings encompasses only gross revenue derived from the carriage of passengers, cargo, or mail originating from the Philippines up to the final destination, whereas other fees such as demurrage and detention fees acquired in the normal course of business fall under regular corporate income tax.² The Court also pronounced that interpretative regulations merely construe or clarify existing statutory provisions without creating new consequences beyond the law, exempting them from public hearing, consultation, publication, and administrative registration requirements.²