FACTS
Philippine Health is a domestic corporation engaged in the dispensation of the following medical services to individuals who enter into health care agreements with – Preventive, Diagnostic and Curative medical services. Individuals enrolled in its health care program pay an annual membership fee.
The Commissioner of Internal Revenue [CIR] sent the petitioner a formal demand letter and the corresponding assessment notices demanding the payment of deficiency taxes. Petitioner protested and filed a petition for review in the Court of Tax Appeals (CTA) seeking the cancellation of the deficiency VAT and DST assessments.
The CTA partially granted the petition ordering the petitioner to pay for the VAT.