BL&B has broad experience planning for and managing audits and various audit issues. It routinely handles BIR examinations at the revenue officer level, either directly or behind the scenes as an adjunct to its clients’ accounting or tax compliance department. B&B also takes charge of a BIR examination at the appellate stage, preparing a comprehensive written protest and conferring and deliberating with the reviewing revenue officers. Tax cases not settled at the administrative level are handled by tax litigators who are accomplished tax lawyers, experienced in transactional planning as well as litigation. BL&B has extensive tax litigation experience at the trial and appellate levels, including before the Court of Tax Appeals, Court of Appeals, and the Supreme Court. BL&B’s tax litigators have represented clients in some of the largest and most complex tax cases in the Philippines.



  • Represented the world’s second largest quoted tobacco group in oral argument before the Supreme Court En Banc in challenging discriminatory provisions of the Philippine tobacco excise tax law.
  • Represented an association of petroleum dealers in oral argument before the Supreme Court En Banc in challenging the constitutionality of the Expanded Value-Added Tax Law.
  • Successfully litigated a tax case before the Court of Tax Appeals on behalf of a Global 100 oil and gas company and obtained in the process a precedent setting decision relating to M&As to the effect that no separate stamp tax is due or payable on the transfer by the absorbed corporation of its assets to the surviving corporation pursuant to the merger, which Congress later adopted by way of an amendment to the National Internal Revenue Code.
  • Successfully litigated a disputed Php 300 million tax assessment for the local unit of the world’s largest pharmaceutical company, resulting in the cancellation of the questioned assessment.



8/F Jollibee Centre, San Miguel Avenue 1605 Pasig City, Philippines
(632) 633-9418
(632) 633-1911; (632) 687-7674

Baniqued Layug & Bello


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