THE COURT of Tax Appeals (CTA) has denied the petition of Ford Group Philippines, Inc. seeking a refund of P202.93 million in alleged excess and unused creditable withholding taxes (CWTs) for 2020, citing the company’s failure to sufficiently prove its entitlement to the refund.
In a 26-page decision dated Oct. 1, 2025, the CTA’s Third Division, through Associate Justice Erlinda P. Manahan, ruled that while Ford filed its refund claim within the prescribed period, it failed to present adequate documents showing that the withheld taxes it sought to recover were declared as part of its 2020 income.
The company earlier asked the Bureau of Internal Revenue (BIR) to refund the alleged overpaid amount, saying it had an overpayment of P580.75 million for 2020, of which P202.93 million represented unutilized CWTs — taxes withheld by clients and other parties on its behalf that were not fully credited in its annual income tax return.
The BIR opposed the claim, arguing that Ford failed to establish a direct link between the income and the taxes withheld and did not provide proof that the taxes were remitted to the government. It added that the company’s failure to submit complete documents at the administrative level rendered its claim “pro forma,” or incomplete.
While the tax court disagreed that missing documents automatically invalidate a claim, it still found Ford’s evidence insufficient.
“Petitioner has not sufficiently proven its entitlement to the present refund claim,” the court said, noting that the burden of proof lies with the taxpayer.
The CTA said that tax refunds are a form of exemption and must therefore be substantiated with clear and complete documentation.
“Refunds need to be proven and their application raised in the right manner as required by law,” the court added, denying Ford’s petition “for lack of merit.” — Erika Mae P. Sinaking
