NFA not exempt from property tax, CTA rules – Manila Bulletin


NFA not exempt from property tax, CTA rules

Lots owned by the National Food Authority (NFA) are subject to property tax (RPT) imposed and collected by local government units (LGU), the Tax Appeal Court (CTA) said in a ruling.

The decision of the second division of the court upheld the decision of the Ligao City, Albay Regional Court of First Instance (RTC) in April 2019.

The RTC denied the NFA’s petition to quash the city government’s over P642,000 deficiency RPT issued for its lot and warehouse in Barangay Calzada, Ligao City

The NFA argued that the agency is a government “instrument” exempt from TPR under the Local Government Code (LGC).

The court said, however, that the NFA is a government owned and controlled corporation (GOCC) whose tax exemption privilege was removed when the LGC was enacted in 1992.

He explained that GOCC is a stock or non-stock company while the government instrument can be vested with corporate powers but does not necessarily become a corporation like the government service insurance system.

Deputy Judge Jean Marie Bacorro-Villena, who drafted the 27-page decision, said that “LGU’s taxing power is the most effective instrument to raise the revenue needed to finance and support the provision of services to population “.


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