06-02-2019, 02:44 PM
Taxes must only be imposed prospectively, unless other provided by such law (Civil Code, Art. 4; Hydro Resources vs. CA, GR No. 80276, December 21, 1990).
The legislative intent evincing that a tax statute should operate retroactively should be explicit and perfectly clear. Thus, a statute should be considered as prospective in its operation, whether it enacts, amends or repeals, unless the language of the statute clearly demands or expresses that it shall have a retroactive effect (Lorenzo vs. Posadas, GR No. L-43082, June 18, 1937).
The legislative intent evincing that a tax statute should operate retroactively should be explicit and perfectly clear. Thus, a statute should be considered as prospective in its operation, whether it enacts, amends or repeals, unless the language of the statute clearly demands or expresses that it shall have a retroactive effect (Lorenzo vs. Posadas, GR No. L-43082, June 18, 1937).