Tax me not: A representative office's tale

Where a particular word or phrase in a statement is ambiguous in itself or is equally susceptible to various meanings, its true meaning may be made clear and specific by considering the company in which it is found or with which it is associated. Put simply, the legal term noscitur a sociis may be interpreted as "birds of the same feather flock together".

Courts have often applied the principle of noscitur a sociis in resolving issues, such as in Commissioner of Internal Revenue versus Shinko Electric Industries Co. (G.R. No. 226287 dated 6 July 2021). While most would not want to be judged by the company they keep, that was not the case for Shinko. In this case, the Supreme Court (SC) decided in favor of Shinko and affirmed that it should be treated like regional or area headquarters (RHQ).