Feb 082017
It is a basic rule that regulations may not enlarge, alter, restrict, or otherwise go beyond the provisions of the law they administer; administrators and implementors cannot engraft additional requirements not contemplated by the legislature.
Five years ago, as a response to reports of smuggling of petroleum and petroleum products, and to ensure that correct taxes are paid and collected, the Secretary of Finance, pursuant to his authority to interpret tax laws and upon the recommendation of the Commissioner of Internal Revenue (CIR), issued Revenue Regulations (RR) No. 2-2012.