The Supreme Court gave its decision on 19 August 2013 in the case of Deutsche Bank AG Manila Branch v. Commissioner of Internal Revenue (G.R. No. 188550). Details of the decision are summarized below. (a) Facts. Deutsche Bank AG Manila Branch (DB Philippines) withheld 15% branch profit remittance tax (BPRT) on its regular banking unit net income remitted to Deutsche Bank Germany (DB Germany) for 2002 and prior taxable years. This amounted to approximately PHP 68 million. DB Philippines later believed that it made an overpayment of the withholding tax, and filed an administrative claim for refund or issuance of...