After a thorough review, the Supreme Court (SC) approved the P600-million judicial compromise agreement between the Bureau of Internal Revenue (BIR) and Citysuper, Inc, which operates Landmark Trinoma mall in Quezon City.
Under the accord, Trinoma will pay the P600-million representing tax deficiencies in 2021.
“[T]his Court finds that it is not contrary to law, morals, good customs, and public policy, and appears to be freely executed by the petitioner (BIR) and private respondent (Citysuper),” part of the SC resolution read. It was released last Monday, Feb. 26.
The decision reversed an earlier ruling by the Court of Tax Appeals, which validated the P2.08 billion assessment notices for 2011 that BIR issued against Citysuper in 2015. The mall operator appealed its case in 2021 citing pandemic-induced business losses.
Citysuper offered to settle its tax obligations subject to the approval of the SC for P600 million. It also filed a motion to reconsider the 2021 decision and manifested its desire to enter into a compromise agreement with BIR that was accomplished in 2022.
The agreement noted that Citysuper, which “operates under the commercial name of Landmark Trinoma,” has paid the P600 million tax deficiencies including P10.2 million in documentary stamp tax. The company is engaged in selling various products through groceries and department stores.
The high court required the parties to abide by its terms and conditions, and to comply strictly and faithfully with their corresponding obligations. “The case is considered closed and terminated. So ordered,” the SC said.
Editor’s Note: This is an updated article. Originally posted with the headline “From P2.8B to P600M: SC accepts QC mall operator tax settlement.”