In a 29 July 2020 decision, the Court of Tax Appeals ordered the Bureau of Internal Revenue to reimburse Jollibee’s Laguna-based central commissary, Zenith Foods Corp., for the expanded withholding tax (EWT), final withholding tax (FWT), and fringe benefit tax (FBT) it paid, including surcharges and interest, in 2004.
The CTA ruled that the BIR’s 2004 tax assessment was void and the BIR’s collection was illegal.
CTA said Zenith only paid the tax deficiency because it could lose its accreditation as an importer for having a delinquent account.
Zenith’s lone witness in the case is Clarisa Hornilla-Guerra, the tax manager of Jollibee Worldwide Pte. Ltd.
Zenith operates a 17-year old food processing plant and serves more than 800 Jollibee and Greenwich stores in and outside the Philippines.