The Philippine Court of Tax Appeals recently issued a decision on whether the Philippine Bureau of Internal Revenue (BIR) can impose an additional assessment after the expiry of the standard three-year period following the submission of a tax return. The case involved a Yamaha distributor, Norkis Trading Co. Inc., which was issued an additional assessment of approximately PHP 286 million (~USD 5.6 million) in July 2014 for an alleged tax deficiency (inclusive of interest and penalties) with respect to the 2006-07 tax year. The assessment was issued based on the BIR's determination that Norkis failed to report a USD 6...