Question

Taxation

The City Treasurer of Marikina issued a Notice of Assessment against Dyna Corp. on March 15, 2025, for unpaid local business tax (LBT) covering taxable years 2020 and 2021. Dyna Corp. filed a written protest before the City Treasurer, arguing: (a) the assessment for taxable year 2020 is void for having been issued beyond the five-year prescriptive period under the Local Government Code; and (b) the assessment for taxable year 2021 is likewise void. The City Treasurer denied both protests, contending that the five-year prescriptive period under the LGC runs from the date of assessment, not from the date the tax became due. (a) Is the City Treasurer's interpretation of the prescriptive period correct? (b) Which of the two assessments, if any, is valid?

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