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Kristine Anne Mercado-Tamayo

Kristine Anne Mercado-Tamayo is a partner and the head of Quisumbing Torres’ Tax Practice Group. She heads the Industrials, Manufacturing & Transportations Industry Group and is also a member of the Consumer Goods & Retail. She has 16 years of experience assisting and advising clients on tax issues relating to corporate restructuring and mergers and acquisitions. Kristine also handles customs and international trade matters, including border and post-clearance disputes. She advocates on clients' behalf in controversies involving disputed assessments, representing clients before the Bureau of Internal Revenue and the Bureau of Customs.
Kristine Anne obtained her Doctor of Law degree from the Ateneo de Manila in 2005. She is cited as a Next Generation Partner in Tax by the Legal 500 Asia Pacific for 2020 to 2023. More recently, she has been named highly regarded lawyer for General corporate tax, and Women in tax by ITR World Tax 2023.

On 27 December 2023, the BIR published RR No. 16-2023 to amend RR No. 2-1998 and impose withholding tax on the gross remittances by e-marketplace operators and digital financial services providers to sellers/merchants. On 11 January 2024, the BIR issued RMC 8-2024 to provide guidance on the timeline and procedures to implement RR No. 16-2023. According to RR No. 16-2023, e-marketplace operators and digital financial services providers are allowed a transitory period of 90 days from the issuance of RMC 8-2024 to comply with the provisions of RR No. 16-2023.

On 8 January 2024, Commissioner of Internal Revenue Romeo D. Lumagui Jr. issued an advisory regarding the cessation of the Bureau of Internal Revenue (BIR)’s collection of the Annual Registration Fee (ARF), in compliance with Republic Act (RA) No. 11976 or the “Ease of Paying Taxes Act.”

The Bureau of Internal Revenue recently issued Revenue Regulations No. 16-2023, which sets out the guidelines on the imposition of withholding tax on gross remittances by electronic marketplace operators and digital financial services providers to online sellers/merchants, in connection with goods and services sold or paid through the former’s platform.
The Regulations took effect on 12 January 2024.

Asia Pacific tax authorities are actively seeking to reduce tax leakages, non-compliance, and what they perceive to be tax avoidance activities. To help you position your business for success in an era of ever-changing tax rules and intense scrutiny, our subject matter experts from across the region and globally will come together to examine key developments. We will discuss the impact of emerging trends and current issues on your business models and strategies, sharing practical tips on how you can maximize opportunities to achieve the best risk mitigation outcomes.

The National Economic Development Authority has issued the implementing rules and regulations of the amended Public Service Act or Republic Act No. 11659, which took effect on 4 April 2023.

On 18 August 2022, a webinar entitled Managing Customs Disputes in the Philippines took place as part of the Asia Pacific IMT webinar series. The collection targets of both the Philippine Bureau of Internal Revenue and the Bureau of Customs have increased to recover the lost government revenue caused by the pandemic. This has resulted in a rise in the imposition of penalties on importers for non-compliance. The webinar provides a brief discussion of the common issues raised during border disputes and post clearance audits, and the remedies available to the importers.