2014 JULY ISSUE
www.bdoalbaromeo.ph
Revenue Memorandum
Circular No. 54 -2014
Revenue Memorandum
Circular No. 55 -2014
Revenue Memorandum
Circular No. 56 -2014
Revenue Memorandum
Circular No. 57 -2014
Revenue Memorandum
Circular No. 58 -2014
Revenue Memorandum
Circular No. 22 -2014
Revenue Memorandum
Circular No. 23 -2014
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REVENUE MEMORANDUM
CIRCULAR NO. 54-2014
If the taxpayer is a
juridical person, there should be
a sworn statement that the
SUBJECT:Clarifying Issues
officer signing the affidavit has
Relative to the Application for
been authorized by the Board of
Value Added Tax (VAT) Refund/ Directors of the company.
Credit under Section 112 of the A decision shall be rendered by
Tax Code, as amended
the Commissioner based only on
the documents submitted by the
DATE: June 11, 2014
taxpayer. The application shall
be denied where the taxpayer
I. Prescriptive Period within
failed to submit the complete
which Administrative Claim for
supporting documents for which
Refund or Tax Credit of Input
the concerned office shall
Taxes shall be made
prepare and issue the
corresponding Denial Letter to
Any VAT-registered person whose the taxpayer.
sales are zero-rated or
effectively zero-rated may apply III. Mandatory 120+30 Day Pewithin two (2) years after the
riod
close of the taxable
quarter when sales were made.
In case of full or partial denial,
The Commissioner has one
or the failure of the
hundred twenty (120) days from
Commissioner to act on the
the date of submission to decide application, the taxpayer
whether or not to grant the claim affected may appeal the decision
for creditable input taxes. If the with the CTA in two ways:
claim for VAT refund or credit is
not acted upon by the
(1) file the judicial claim within
Commissioner within the 120-day thirty (30) days after the
period, this will be deemed to
Commissioner denies the claim
be a denial of the application for within the 120-day period, or
tax refund or credit.
(2) file the judicial claim within
thirty (30) days from the expiraII. Filing and Processing of
tion of the 120-day period if the
Administrative Claims
Commissioner does not act within
the 120-day period.
The application must be
accompanied by complete
supporting documents with a
statement under oath
attesting to the completeness
of the submitted documents and
that the said documents are the
only
documents which the
taxpayer will present to support
the claim.
TAX DIGEST
IV. Exception to the Mandatory
and Jurisdictional Nature of the
120+30 day Period (BIR Ruling
No. DA-489-03 dated 10
December 2003)
As an exception, it was
emphasized that from the time of
issuance of BIR Ruling No.
DA-489-03 on
December 10, 2003 up to its
reversal by the Supreme Court in
the Aichi case on October 6, 2010
(or a period of almost 7 years),
taxpayers need not wait for the
lapse of the 120-day period
before it could seek judicial
relief with the CTA by way of
Petition for Review. This
exception is limited to cases of
premature filing (filing of judicial
claim prior to the lapse of the
120-day period) and does not
extend to late filing of a judicial
claim.
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TAX DIGEST
REVENUE MEMORANDUM
CIRCULAR NO. 55-2014
REVENUE MEMORANDUM
CIRCULAR NO. 56-2014
REVENUE MEMORANDUM
CIRCULAR NO. 57-2014
SUBJECT: Clarifying the
livestock and poultry feeds or
ingredients used in the
manufacture of
finished feeds to be exempt
from Value-Added Tax (VAT)
under Sec. 4.109-1(B)(1)(b) of
Revenue
Regulations No. 16-2005
SUBJECT: Extending the
Deadline for Submission of Sales
Reports for the Months of May
and June 2014 via the
Enhanced and Integrated
Electronic Accreditation and
Registration (EACCREG) and
Electronic Sales Reporting
(eSales) Systems Pursuant to
Revenue
Memorandum Circular
No. 45-2014
SUBJECT: Clarifying the
Provisions of Revenue
Regulations No. 1-2013 on the
Use of Electronic Tax
Remittance Advice
DATE: June 17, 2014
The BIR clarifies that that the
sale or importation of ingredients
which may also be used for the
production of food for human
consumption shall be subject to
VAT. Thus, for the sale or
importation of livestock and
poultry feeds or
ingredients used in the
manufacture of finished feeds to
be exempt from VAT, there must
be a showing that the same is
unfit for human consumption or
that the ingredient cannot be
used for the production of food
for human
consumption as certified by the
Food and Drug Administration
(FDA).
DATE: June 27, 2014
This Circular has been issued to
extend the deadline to July 31,
2014. This shall also include sales
for the months of May and June
2014, and no penalties shall be
imposed. Sales for the month of
July shall be reported on or
before the 8th (for taxpayers
whose last digit of the 9-digit TIN
is an even
number) or 10th (for taxpayers
whose last digit of the 9-digit TIN
is an odd number) day of August
2014. All taxpayers with CRM/
POS machines and other sales
machines with manually issued
Permits to Use (PTUs) are
mandated to re-register in the
enhanced and integrated
eAccReg and eSales systems on or
before July 31, 2014.
DATE: July 15, 2014
Under the provisions of RR No.
1-2013, the BIR gives emphasis
and clarifies that all NGAs are
mandated to enroll with and use
the Electronic Filing and
Payment System (eFPS) in their
filing of their applicable tax
returns within the prescribed
periods, as follows:
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TAX DIGEST
I. Regular Tax Returns Filed by NGAs
II. Tax Returns Filed by NGAs Exercising Proprietary Functions
For all NGAs which are exercising proprietary functions, the tax returns enumerated below
shall likewise be filed within the corresponding indicated periods using the Bureau’s eFPS
facility. However, the taxes due thereon shall be paid through the bank debit system of
the eFPS’ Authorized Agent Banks (AABs) where the NGA should be duly enrolled, and NOT
through the eTRA System.
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Based on these clarifications, it
should be observed in Table No. 1
above under the “Regular Tax
Returns Filed by NGAs” that the
eTRA System covers only the
payment of withholding taxes
through the eTRA generated
therefrom. Therefore, it does
not cover other internal revenue
taxes. Considering that the eTRA
System is mandated to be used as
the platform for the payment of
the withholding taxes,
manual forms of TRA are no
longer needed. This means that
manual forms are prohibited to
be used by NGAs, unless the use
of manual TRA forms are
expressly allowed by written
issuance or advisory issued by the
Commissioner of Internal
Revenue under certain
exceptional circumstances.
REVENUE MEMORANDUM CIRCULAR NO. 58-2014
SUBJECT: Publishing the Full
Text of Supreme Court
Resolution dated June 25, 2014
on the Withholding of Tax from
the Special Allowance for the
Judiciary
DATE: July 22, 2014
A.M. No. 12-4-6-SC (Re: BIR
Letter of Authority to Examine
Supreme Court Books of Account
and Other Accounting Records)
– The Court resolved to approve
the withholding and remittance
of the correct amount of tax
required to be deducted and
withheld from the Special
Allowance for the Judiciary (SAJ)
of officials and employees, as
well as the withholding of the
corresponding taxes from the
following:
TAX DIGEST
(1) The monthly SAJ of
incumbent justices, judges and
Judiciary
officials with the equivalent rank
of a Court of Appeals justice or
Regional Trial Court judge;
(2) The monthly special
allowance in an amount
equivalent to the SAJ being
received by judiciary officials not
included in item no. 1; and
(3) The additional allowance
from the surplus of the SAJ Fund
that may be authorized to be
given to judiciary officials and
employees who are not direct
beneficiaries under Republic Act
No. 9227.
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REVENUE MEMORANDUM ORDER
NO. 22-2014
SUBJECT: Supplemental
Guidelines, Policies and
Procedures in the Accreditation
of Importers and Customs
Brokers as Embodied in
Revenue
Memorandum Order No.
10-2014
DATE: June 20, 2014
COMPLIANCE LEVEL LEVEL DESCRIPTION
b.1. First Level
Importers or brokers that have
fully satisfied the
accreditation criteria under
Section 3.2 of RMO 10-2014 and
such tax compliance
requirements were already
verified/validated from all
concerned offices of the BIR
b.2. Second Level
Importers or brokers that
appear to have satisfied the
prescribed accreditation
criteria but the same require
further verification and/
validation from other
concerned BIR offices;
applications which were not
able to submit the Certificate of
Good Standing, but have already
applied with SEC for such
The processing of the
applications for BIR ICC and BIR
BCC shall be governed by the
following transitory policies and
guidelines:
b.3. Third Level
Taxpayers or brokers that were
verified to have failed all the
accreditation criteria under
Section 3.2 of RMO 10-2014;
includes importers or brokers
who may have satisfied some
criteria but were confirmed to
have failed some major
accreditation criteria such as
any of the following: tagged as a
“Cannot Be Located” or CBL
taxpayer; with open valid
stop-filer cases; with criminal
cases in the DOJ or courts; with
listed accounts receivables that
are already final, executory, and
demandable. Likewise included
under this level are applications
which were not received due to
incomplete requisite documents
TAX DIGEST
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3. ARMD shall issue Regular BIR ICC
or BIR BCC that is valid for three (3)
years to importers or brokers that
fall under the Level 1
Category while BIR NDIAB shall be
issued to those that are determined
to be classified under Level 3.
Provisional BIR ICC or BIR BCC that
is valid for six (6) months shall be
issued to those that fall under the
Level 2 Classification while still
awaiting the results of the
verification of the applicants’ tax
compliance pursuant to the set accreditation criteria.
The ARMD shall either issue a regular
BIR ICC/BIR BCC or BIR NDIAB to the
concerned importers or brokers
before the expiration of the
six-month period, and based on the
results of the verifications or
validations made. However, those
applications which were already
issued BIR ICC or BIR BCC valid for
three (3) months based on the
criteria herein provided shall no
longer be extended in the event the
applicant has not resolved the
deficiencies noted when the
provisional BIR ICC or BIR BCC was
granted. Upon the expiration of the
three-month validity period of the
provisional BIR ICC or BIR BCC,
applicants shall either receive BIR
ICC or BIR BCC valid for three (3)
years or a denial; and
4. In case a regular BIR ICC or BIR
BCC shall be issued to an importer
or broker that was previously issued
a Provisional BIR ICC or BIR BCC, the
validity period of three (3) years
shall be reckoned from the effective
or issue date of the Provisional BIR
ICC or BIR BCC.
The processing of applications for
BIR accreditation shall only apply to
applicants that are included in the
existing list of importers and brokers
with valid BOC accreditations
provided the applications are
received by the BIR before June 30,
2014. Accordingly, applications not
qualified under this transitory
provision shall be processed
pursuant to RMO No. 10-2014 and
the applicants are automatically not
eligible for the issuance of
Provisional BIR ICCs or BIR BCCs
depending on which is applicable.
REVENUE MEMORANDUM ORDER
NO. 23-2014
SUBJECT: Obligations of
Government Agencies, Bureaus and
Instrumentalities as
Withholding Agents
DATE: June 20, 2014
This Order is issued to clarify and
consolidate the responsibilities of
the public sector to withhold taxes
on its transactions as a customer (on
its purchases of goods and services)
and as an employer
(on compensation paid to its officials
and employees).
Obligation to Withhold on
Purchases of Goods and Services
All government offices including
government-owned or controlled
corporations, as well as provincial,
city and municipal governments are
constituted as withholding agents
for purposes of the creditable tax
required to be withheld on the
following:
A.Withholding of Creditable
Income Tax
- Income payments to certain
contractors – On gross payments to
the following contractors, whether
individual or corporate —
Two percent (2%)
TAX DIGEST
These Contractors include:
(1) General engineering
contractors — Those whose principal
contracting business in connection
with fixed works requiring
specialized engineering knowledge
and skill including the following
divisions or subjects:
(a) Reclamation works;
(b) Railroads;
(c) Highways, streets and roads;
(d) Tunnels;
(e) Airports and airways;
(f) Waste reduction plants;
(g) Bridges, overpasses, underpasses
and other similar works;
(h) Pipelines and other systems for
the transmission of petroleum and
other liquid or gaseous substances;
(i) Land leveling;
(j) Excavating;
(k) Trenching;
(l) Paving; and
(m) Surfacing work.
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(2) General Building contractors
— Those whose principal
contracting business is in
connection with any structure
built, for the support, shelter
and enclosure of persons,
animals, chattels, or movable
property of any kind, requiring
in its construction the use of
more than two unrelated building
trades or crafts, or to do or
superintend the whole or any
part thereto. Such structure
includes sewers and
sewerage disposal plants and
systems, parks, playgrounds, and
other recreational works,
refineries, chemical
plants and similar
industrial plants requiring
specialized engineering
knowledge and skills,
powerhouse, power plants and
other utility plants and
installation, mines and
metallurgical plants, cement and
concrete works in connection
with the
above-mentioned fixed works.
(3) Specialty Contractors — Those
whose operations pertain to the
performance of
construction work requiring
special skill and whose principal
contracting business
involves the use of specialized
building trades or crafts.
(a) Filling, demolition and
salvage work contractors and
operators of mine drilling
apparatus;
(b) Operators of dockyards;
(c) Persons engaged in the
installation of water system,
and gas or electric light, heat or
power;
(d) Operators of stevedoring,
warehousing or forwarding
establishments;
(e) Transportation contractors
which include common carriers
for the
carriage of goods and
merchandise of whatever kind by
land, air or
water, where the gross payments
by the payor to the same payee
amounts to at least two thousand
pesos (P2,000) per month,
regardless of the number of
shipments during the month;
(f) Printers, bookbinders,
lithographers and publishers
except those principally engaged
in the publication or
printing of any
newspaper, magazine, review or
bulletin which appears at regular
intervals, with fixed prices for
subscription and sale;
(g) Messengerial, janitorial,
private detective and/or security
agencies, credit and/or
collection agencies and other
business agencies;
(h) Advertising agencies,
exclusive of gross payments to
media;
(i) Independent producers of
television, radio and stage
performances or shows;
(j) Independent producers of
"jingles";
TAX DIGEST
(k) Labor recruiting agencies;
(l) Persons engaged in the
installation of elevators, central
air conditioning units, computer
machines and other equipment
and machineries and the
maintenance services thereon;
(m) Persons engaged in the sale
of computer services;
(n) Persons engaged in
landscaping services;
(o) Persons engaged in the
collection and disposal of
garbage;
(p) TV and radio station
operators on sale of TV and radio
airtime; and
(q) TV and radio blocktimers on
sale of TV and radio commercial
spots.
- Income payments to its local/
resident supplier of goods and
local/resident supplier of
services other than those covered
by other rates of withholding
tax. —
Supplier of goods — One percent
(1%)
Supplier of services—Twopercent
(2%)
However, casual government
purchases amounting to not
more than Ten thousand pesos
(P10,000.00) are not subject
to the 1% or 2% withholding of
income tax.
- Rentals — On gross rental for
the continued use or possession
of real property used in business
which the government has not
taken or is not taking title, or
in which it has no equity — Five
percent (5%).
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9
B. Allowances, bonuses,
honoraria or benefits
received by employees and
officials in the
Judicial Branch, such as the
Additional
Compensation (ADCOM),
Extraordinary and
Miscellaneous Expenses (EME),
Monthly Special Allowance from
the Special Allowance for the
Judiciary,
Additional Cost of Living
Allowance from the
Judiciary Development Fund,
Productivity
Incentive Benefit, Grocery
Allowance, Clothing Allowance,
Emergency Economic Allowance,
Year-End
Bonus, Cash Gift, Loyalty Cash
Award (Milestone Bonus), SC
Christmas Allowance, anniversary
bonuses and other allowances,
bonuses and
benefits given by the Supreme
Court of the
Philippines and all other courts
and offices under the Judicial
Branch to their officials and
employees, subject to the
exemptions
enumerated herein.
C.Compensation for services in
whatever form paid, including,
but not limited to allowances,
bonuses, honoraria or benefits
received by
employees and officials in the
Constitutional
bodies (Commission on Election,
Commission on Audit, Civil
Service Commissioner) and the
Office of the Ombudsman,
subject to the
exemptions enumerated herein.
D. Allowances, bonuses,
honoraria or benefits received
by employees and officials in
the
Executive Branch, such as the
Productivity
Enhancement Incentive (PEI),
Perfomance-Based Bonus,
anniversary bonus and
other allowances, bonuses
and benefits given by the
departments, agencies and
other offices
under the Executive Branch to
their officials and employees,
subject to the exemptions
enumerated herein.
Any amount paid either as
advances or
reimbursements for expenses
incurred or
reasonably expected to be
incurred by the
official and employee in the
performance of his/her duties
are not compensation subject
to
withholding, if the following
conditions are
satisfied:
1.The employee was duly
authorized to incur such
expenses on behalf of the
government; and
2.Compliance with
pertinent laws and
regulations on accounting and
liquidation of advances and
reimbursements, including,
but not limited to,
withholding tax rules. The
expenses should be duly
receipted for and in the name
of the government office
concerned.
TAX DIGEST
NON-TAXABLE COMPENSATION
INCOME —
The following income received by
officials and
employees in the public sector are
not subject to
income tax and withholding tax on
compensation:
A.Thirteenth (13th) Month Pay and
Other Benefits not exceeding Thirty
Thousand Pesos (P30,000.00) paid or
accrued during the year. Any amount
exceeding Thirty Thousand Pesos
(P30,000.00) are taxable
compensation. This includes:
1.Benefits received by officials and
employees of the national and local
government pursuant to Republic
Act No. 6686 (“An Act Authorizing
Annual Christmas Bonus to National
and Local Government Officials and
Employees Starting CY 1988”);
2.Benefits received by employees
pursuant to
Presidential Decree No. 851 (“Requiring All
Employers to Pay Their Employees
a 13th Month Pay”), as amended by
Memorandum Order No. 28, dated
August 13, 1986;
3.Benefits received by officials and
employees not covered by Presidential Decree No. 851, as amended by
Memorandum Order No. 28, dated
August 13, 1986;
4.Other benefits such as Christmas
bonus, productivity incentives bonus,
loyalty award, gift in cash or in kind
and other benefits of similar nature
actually received by officials and employees of government offices,
including the Additional
Compensation Allowance (ACA)
granted and paid to all officials and
employees of the National
Government Agencies (NGAs)
including state universities and
colleges (SUCs),
government-owned and/or controlled
corporations (GOCCs), government
financial institutions (GFIs) and Local
Government Units (LGUs).
10
B.Facilities and privileges of
relatively small value or “De
Minimis Benefits” as defined in
existing issuances and
conforming to the ceilings
prescribed therein;
C.Fringe benefits which are
subject to the fringe
benefits tax under Section 33 of
the NIRC, as
amended;
D.Representation and
Transportation Allowance (RATA)
granted to public officers and
employees under the General
Appropriations Act;
E.Personnel Economic Relief
Allowance (PERA) granted to
government personnel;
F.The monetized value of leave
credits paid to
government officials and
employees;
G.Mandatory/compulsory GSIS,
Medicare and Pag-Ibig
Contributions, provided that,
voluntary contributions to these
institutions in
excess of the amount
considered mandatory/
compulsory are not excludible
from the gross income of the
taxpayer and hence, not exempt
from Income Tax and Withholding
Tax;
H.Union dues of individual
employees;
I.Compensation income of employees in the public
sector with compensation income
of not more than the Statutory
Minimum Wage (SMW) in the
non-agricultural sector
applicable to the place where
he/she is assigned;
J.Holiday pay, overtime pay,
night shift differential pay, and
hazard pay received by Minimum
Wage
Earners (MWEs);
K.Benefits received from the
GSIS Act of 1937, as amended,
and the retirement gratuity/
benefits received by
government officials and
employees under pertinent
retirement laws;
L.All other benefits given which
are not included in the above
enumeration but are exempted
from
income tax as well as
withholding tax on
compensation under existing
laws, as confirmed by BIR.
CONFIRMATION OF TAX
TREATMENT – Confirmation of
Exemption of the benefit shall
be secured through a ruling
issued by the Commissioner of
Internal Revenue or his duly
authorized representative.
PERSONS RESPONSIBLE FOR
WITHHOLDING
The following officials are duty
bound to deduct,
withhold and remit taxes:
a)For Office of the
Provincial Governmentprovince- the Chief
Accountant, Provincial
Treasurer and the Governor;
b)For Office of the City
Government-cities- the Chief
Accountant, City Treasurer and
the City Mayor;
c)For Office of the Municipal
Government-municipalities- the
Chief Accountant, Municipal
Treasurer and the Mayor;
d)Office of the BarangayBarangay Treasurer and
Barangay Captain;
e)For NGAs, GOCCs and other
Government Offices, the Chief
Accountant and the Head of
Office or the Official holding
the highest position (such as
the President, Chief Executive
Officer, Governor, General Manager).
TAX DIGEST
PENALTY PROVISION
In case of non-compliance with their
obligation as withholding agents, the
abovementioned persons shall be
liable for the following sanctions:
A.Failure to Collect and Remit Taxes
(Section 251, NIRC)
“ Any person required to
withhold, account for, and remit any
tax imposed by this Code or who
willfully fails to withhold such tax,
or account for and remit such tax, or
aids or abets in any manner to evade
any such tax or the payment thereof,
shall, in addition to other penalties
provided for
under this Chapter, be liable upon
conviction to a penalty equal to the
total amount of the tax not withheld,
or not accounted for and remitted.”
B.Failure to File Return, Supply
Correct and Accurate
Information, Pay Tax Withhold and
Remit Tax and Refund
Excess Taxes Withheld on
Compensation (Section 255, NIRC)
“Any person required under this
Code or by rules and regulations
promulgated thereunder to pay any
tax make a return, keep any record,
or supply correct the accurate
information, who willfully fails to
pay such tax, make such return, keep
such record, or supply correct and
accurate information, or withhold
or remit taxes withheld, or refund
excess taxes withheld on
compensation, at the time or times
required by law or rules and
regulations shall, in
addition to other penalties
provided by law, upon
conviction thereof, be punished by
a fine of not less than Ten thousand
pesos (P10,000) and suffer
imprisonment of not less than one
(1) year but not more than ten (10)
years.
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Any person who attempts to make it appear for
any reason that he or another has in fact filed
a return or statement, or actually files a return
or statement and subsequently withdraws the
same return or statement after securing the
official receiving seal or stamp of receipt of
internal revenue office wherein the same was
actually filed shall, upon conviction therefor, be
punished by a fine of not less than Ten thousand
pesos (P10,000) but not more than Twenty
thousand pesos (P20,000) and suffer
imprisonment of not less than one (1) year but
not more than three (3) years.”
C.Violation of Withholding Tax Provisions
(Section 272, NIRC)
“ Every officer or employee of the Government
of the Republic of the Philippines or any of its
agencies and instrumentalities, its political
subdivisions, as well as government-owned or
controlled corporations, including the Bangko
Sentral ng Pilipinas (BSP), who is charged with
the duty to deduct and withhold any internal
revenue tax and to remit the same is guilty of
any offense herein below specified shall, upon
conviction for each act or omission be punished
by a fine of not less than Five thousand pesos
(P5,000) but not more than Fifty thousand
pesos (P50,000) or suffer imprisonment of not
less than six (6) months and one (1) day but not
more than two (2) years, or both:
1. Failing or causing the failure to deduct and
withhold any internal revenue tax under any of
the withholding tax laws and implementing rules
and regulations; or
2. Failing or causing the failure to remit taxes
deducted and withheld within the time
prescribed by law, and implementing rules and
regulations; or
3. Failing or causing the failure to file return or
statement within the time prescribed, or
rendering or furnishing a false or fraudulent
return or statement required under the
withholding tax laws and rules and regulations.”
TAX DIGEST
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TAX DIGEST
LOCATIONS
Makati
7/F Multinational Bancorporation Centre
6805 Ayala Avenue, Makati City 1226 Philippines
Telephone (+63 2) 844 2016
Fax
(+63 2) 844 2045
Email address:cpas@bdoalbaromeo.ph
Bacolod
3/F Capitol Subdivision Building
15th Lacson Street, Bacolod City 6100 Philippines
Telephone (+63 34) 433 3878
(+63 34) 435 8386
(+63 34) 709 1796
Fax
(+63 34) 433 3879
Email address: bacolod@bdoalbaromeo.ph
Cebu
2/F Block A, Mactan Marina Mall MEPZ 1, Ibo
Lapu-Lapu City, Metro Cebu 6015 Philippines
Telephone (+63 32) 340 4037
(+63 32) 494 0306
Fax
(+63 32) 340 4033
Email address: cebu@bdoalbaromeo.ph
Cagayan de Oro
2/F Leonila Neri Building Don Apolinar Velez & C.
Pacana Streets, Cagayan de Oro City 9000
Philipppines
Telephone (+63 88) 856 4532
(+63 88) 852 4214
(+63 88 22) 727 431
Fax
(+63 88 22) 725 082
Email address: cdo@bdoalbaromeo.ph
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Alba Romeo & Co., a Philippine professional partnership, is a member of BDO International Limited, a UK company Limited by guarantee, and forms part of the international BDO network of
independent member firms.
BDO is the brand name for the BDO network and for each of the BDO member firms.