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CTA bars BIR from collecting P8.6B Marcos estate tax from SMC shares
The Freeman
|August 25, 2025
The Court of Tax Appeals (CTA) First Division has partially granted a petition by San Miguel Corp. (SMC), stopping the Bureau of Internal Revenue (BIR) from collecting P8.6 billion in estate taxes from the estate of the late president Ferdinand Marcos Sr.
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In a decision promulgated on August 14, the tax appellate court ruled that the SMC shares in question are the exclusive property of the late businessman Eduardo Cojuangco Jr., and therefore cannot be used to settle the tax liabilities of the Marcos estate.
The ruling reverses and sets aside the November 19, 2024 letter of BIR Commissioner Romeo Lumagui Jr., which the agency described as its “final decision” to collect estate taxes from the SMC shares through summary remedies such as distraint.
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