EXCLUSIVE APPELLATE JURISDICTION CIVIL CASES
CTA EN BANC
Instances Nature of the Case
1. Decisions of the RTC in the exercise of a. Local tax cases
their appellate jurisdiction b. Collection cases involving claims with a
Jurisdiction principal amount of less than Php1
Million for taxes and fees, exclusive of
of the charges and other applicable penalties
c. Criminal offenses arising from
Court of Tax violations of the NIRC or CMTA or any
other laws administered by the BIR or the
Appeals BOC where the principal amount of taxes
and fees, exclusive of charges and other
applicable penalties is less than Php1
Million.
2. Decisions of the CTA division in the Collection cases involving claims with a
exercise of its original jurisdiction principal amount of Php1 Million or more
for taxes and fees, exclusive of charges
and other applicable penalties
3. Decisions of the Central Board of Assessment and taxation of real property
Assessment Appeals in the exercise of as decided by the Provincial or City Board
its appellate jurisdiction of Assessment Appeals
EXCLUSIVE APPELLATE JURISDICTION CIVIL CASES
CTA DIVISION
Instances Nature of the Case
1. Decisions of or Inaction by the Disputed assessments, refunds of
Jurisdiction Commissioner of Internal Revenue internal revenue taxes and penalties in
relation thereto.
of the Also includes other matters arising out
of the NIRC and other laws
Court of Tax administered by the BIR. These
necessarily include RRs, RMOs and
Appeals RMCs.
2. Decisions of the Commissioner of a. Cases involving liability for customs
Customs duties, fees and other charges
(seizures, detention) and penalties in
relation thereto
b. Other matters arising out of the
CMTA and other laws that are
administered by the BOC
EXCLUSIVE APPELLATE JURISDICTION CIVIL CASES
CTA DIVISION
Instances Nature of the Case
3. Decisions of the Secretary of Customs cases elevated for automatic
Jurisdiction Finance review when position of the COC is
adverse to the Government
of the 4. Decisions of the Secretary of Trade Cases involving non-agricultural
Court of Tax and Industry products or articles
Appeals 5. Decisions of the Secretary of
Agriculture
Cases involving agricultural products or
articles
6. Decision of the RTC in the exercise Local Tax Cases
of original jurisdiction
JURISDICTION OVER CRIMINAL CASES
CTA EN BANC
Instance Nature of the Case
Exclusive appellate jurisdiction a. Decisions, resolutions or orders on
Jurisdiction motions for reconsideration or new
trial of the CTA division in the exercise
of the of its exclusive original and appellate
jurisdiction
Court of Tax b. Decisions, resolutions or orders of the
Appeals RTC in the exercise of their appellate
jurisdiction
JURISDICTION OVER CRIMINAL TAX CASES
CTA DIVISION
Instances Nature of the Case
Exclusive original jurisdiction Criminal offenses for violations of the NIRC or
CMTA and other laws as administered by the BIR
Jurisdiction or BOC where the principal amount of taxes and
fees, exclusive of charges and penalties claimed
of the Exclusive appellate jurisdiction
is PHP1 Million or more
a. Appeals from judgments, resolutions or
Court of Tax orders of the RTC in the exercise of their
original jurisdiction for violations of the NIRC
Appeals or CMTA and other laws as administered by
the BIR or BOC where the principal amount
of taxes and fees, exclusive of charges and
penalties claimed is less than PHP1 Million
or when there is no specific amount
claimed
b. Criminal offenses over petitions for review of
decisions by the RTC in the exercise of their
appellate jurisdiction over tax cases originally
decided by MTCs or MCTCs.
JURISDICTION OVER CRIMINAL TAX CASES
RTC
Instance Nature of the Case
Exclusive original jurisdiction Criminal offenses for violations of the NIRC or
Jurisdiction CMTA and other laws as administered by the BIR
or BOC where the principal amount of taxes and
of the fees, exclusive of charges and penalties claimed
is less than PHP1 Million or when there is no
Court of Tax specific amount claimed
Appeals
Source: KPMG Supplemental Tax Reviewer 2019
