Shell Pilipinas Corp. (SHLPH) is studying legal actions to recover over P4 billion in taxes it paid under protest to the government for past alkylate importations, the company said after the Court of Tax Appeals (CTA) en banc affirmed that alkylate is not subject to excise tax.
The CTA en banc decision, dated Nov. 5, 2025, denied consolidated petitions for review filed by the Bureau of Customs (BOC) and the Commissioner of Internal Revenue (CIR), upholding an earlier ruling by the CTA Special Second Division.
The division had invalidated CIR Document No. M-059-2012 and a related letter from the Collector of Customs of the Port of Batangas, which sought to impose taxes on SHLPH’s alkylate importations.
“The CTA en banc decision affirms SHLPH’s position that alkylate is not subject to excise tax. Once the Decision becomes final, SHLPH will consider the necessary legal actions to recover amounts previously paid to the government under protest for its past alkylate importations,” the second-biggest oil company in the Philippines said in a stock exchange disclosure Wednesday.
The CTA rulings prohibit the government from collecting excise taxes and value-added tax on Shell’s alkylate importations.
Shell, which imported alkylate as a blending component for unleaded gasoline, remitted over P4 billion under protest as of 2023, covering alleged excise taxes and VAT on fuel blending components used in its refinery from 2014 to 2020.
The company is said it is no longer importing alkylate.
Shell previously said that it remitted the amount under protest while “taking into consideration the current economic challenges of the country as well as ensuring continued operations, uninterrupted imported fuel supply and welfare of our motoring public and consumers.”
