Extinguishment of Tax Liability Incurred under RA No. 1612

December 4, 1958 BIR RULING NO. 699-58 2nd Indorsement Respectfully returned to the Regional Director, Regional District No. 3, the within papers bearing on the request for a ruling as to whether or not the repeal of Republic Act 1612 by Republic Act 1856, in effect extinguished the tax liability incurred under Republic Act 1612. LLpr Laws are prospective in operation. "The rule favoring a prospective construction of statutes is applicable to statutes which repeal tax laws. Accordingly, it is held that where such statute is not made retroactive, a tax assessed before the repeal is collectible afterwards; and where taxes are levied under a law which is repealed by a subsequent act, unless it appears clearly that the legislature intended the repeal to work retrospectively, it will be assumed that it intended the taxes to be collected according to the laws in force when they are levied." (Cooley, Taxation, Sec. 538, Vol. 2; Intestate Estate of the late Jacinto Co vs. Collector of Internal Revenue, G.R. L-9352). A close perusal of the provisions of Republic Act 1856, does not show any indication of the intention of Congress to have the same operate retrospectively. Consequently, taxes assessed and/or due and collectible prior to the repeal may still be collected by the government. prll (SGD.) MELECIO R. DOMINGO Acting Commissioner of Internal Revenue