The Supreme Court has ordered the Bureau of Internal Revenue to issue tax credit certificates amounting to P6.28 million in favor of United International Pictures, which overpaid its income taxes from 1996 to 1998.

Associate Justice Renato Corona of the court’s First Division upheld the Court of Appeals decision that sustained the ruling rendered by the Court of Tax Appeals directing the refund or the grant of tax credits to UIP.

The high court emphasized that the appellate court did not err in denying the appeal of the Internal Revenue to reverse the CTA decision granting the refund to UIP, an international movie producer.

“Under our tax system, the CTA is a highly specialized body that reviews tax cases. For this reason, its findings of facts are binding on the SC unless such findings are not supported by substantial evidence,” Corona said.

“We find no reason to disturb the CTA’s findings of facts,” the SC ruled, even as it denied the petition filed by the Internal Revenue.

Senior Associate Justice Leonardo Quisumbing, Ma. Alicia Austria-Martinez, Conchita Carpio-Morales and Teresita Leonardo-de Castro concurred with the ruling.

UIP said it paid the BIR P5,791,194 in 1996 and P4,578,574 in 1997 in excess income taxes and pointed out it was entitled to a refund of P10,369,768 as of June 1998.

The tax court only granted a refund or issuance tax credit certificates in the amount of P6,285,892.05.

UIP complied with all the requirements for the refund of creditable withholding taxes. Rey E. Requejo