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"A CONDOMINIUM CORPORATION IS NOT SUBJECT TO LBT ABSENT PROOF OF A PROFIT-ORIENTED BUSINESS, AS ASSOCIATION DUES AND ASSESSMENTS COLLECTED SOLELY TO FUND THE MAINTENANCE AND ADMINISTRATION OF COMMON AREAS ARE NOT COMMERCIAL REVENUES; THUS, THE TAXPAYER WAS NOT A TAXABLE CONTRACTOR UNDER THE TAGUIG REVENUE CODE. The liability for Local Business Tax (LBT) presupposes that the taxpayer is engaged in “business,” meaning trade or commercial activity regularly pursued as a means of livelihood or with a view to profit; therefore, the mere receipt of money or collection of assessments does not, by itself, establish that an entity is engaged in a taxable business. Here, the taxpayer, a condominium corporation organized under the Condominium Act, was legally restricted to holding the common areas, managing and administering the condominium project, and undertaking acts necessary, incidental, or convenient to those purposes. Its Articles of Incorporation and By-laws were consistent with these statutory limitations and did not authorize activities directed toward the pursuit of livelihood or profit. The association dues, membership fees, and other assessments collected from unit owners were likewise not revenues earned from a commercial enterprise or consideration for services rendered for a fee; rather, they constituted a common fund used to pay for the maintenance, repair, improvement, reconstruction, and administrative expenses of the condominium project and common areas for the benefit of the unit owners. Consequently, the taxpayer could not be treated as a contractor under the Taguig Revenue Code merely because it collected these assessments, and the LGU failed to present sufficient evidence that the taxpayer was engaged in any other profit-oriented activity. The Supreme Court has recognized that condominium corporations generally do not engage in trade or business when managing and maintaining common areas for the benefit of unit owners and are therefore generally not subject to local business taxation, irrespective of a local ordinance attempting to impose such tax. Although a condominium corporation may potentially become liable for LBT if it is proven to have engaged in activities for profit, no such activities were alleged or established in this case; the assessment was based solely on the collection of assessments used to defray authorized condominium expenses.  [City Treasurer of Taguig City v. Cedacrest Condominium Corporation, CTA EB No. 3061 (RTC SCA No. 291), March 31, 2026; see also City Treasurer of Taguig City v.  Rosewood Pointe Residences Condominium Corporation, CTA EB No. 3008, (SCA Case No. 298 and MeTC Civil Case No. 22-4575) November 27, 2025]"

"A HOLDING COMPANY THAT MERELY OWNS SHARES AND RECEIVES DIVIDENDS, WITHOUT BSP AUTHORIZATION OR REGULAR FINANCIAL-INTERMEDIARY ACTIVITIES, IS NOT A BANK, FINANCIAL INSTITUTION, OR QUALIFIED NBFI SUBJECT TO LBT ON GROSS RECEIPTS UNDER THE LGC; ORDINANCE CANNOT EXPAND THE LGU’S DELEGATED TAXING POWER. An LGU may impose LBT on the gross receipts of banks and other financial institutions, including qualified non-bank financial intermediaries (NBFIs), but the taxing power of an LGU is merely delegated and must be strictly construed, with any doubt resolved against the municipality. LGC permits the imposition of LBT on the specified gross receipts of banks and other financial institutions, while LGU also defines the entities covered, and it generally prohibits LGUs from imposing income taxes, except on banks and other financial institutions. An entity is considered an NBFI only if the requisites for such classification concur, including BSP authorization to perform quasi-banking functions, principal functions involving the lending, investing, or placement of funds or evidence of indebtedness or equity, and the regular and recurring performance of recognized financial intermediary activities. Applying these rules, the taxpayer’s ownership of shares in a corporation and receipt of dividends did not make it a bank, financial institution, or NBFI because taxpayer was not authorized by the BSP to perform quasi-banking functions and did not regularly or recurringly receive funds from one group for lending or investment with another, principally acquire debt or equity securities using funds received, or borrow against, lend on, or trade in debt or equity securities. The taxpayer was instead a holding company, whose principal purpose was to hold shares in another company to control its policies, and any investment activity was merely incidental to that purpose. The Court therefore distinguished the taxpayer  from financial intermediaries that actively deal with public funds. Consequently, the assessment of LBT on the taxpayer’s dividends had no legal basis, and the local ordinance could not expand the taxing authority granted to the City by the LGC. [Atty. Voltaire Enriquez in his capacity as the City Treasurer of Taguig City v. La Lumiere Holdings, Inc., CTA AC No. 346, December 16, 2025; see also Enriquez v. Rice Creek Holdings, Inc., CTA AC NO 322 (RTC Civil Case No. 663) November 12, 2025, Enriquez v. Chrismon Investments, Inc., CTA AC No 323, February 4, 2026]"

"Pursuant to the Bureau of Internal Revenue’s authority to regulate tax administration, Revenue Memorandum Order (RMO) No. 14-2026 partially revokes certain procedural provisions of RMO No. 4-2025 (particularly Section E) regarding the verification and handling of Cannot Be Located (CBL) taxpayers."