'THE tax code is a road map for law-abiding citizens and businesses to pay what they fairly owe, not an obstacle course to be gamed and gotten around.' – Max Baucus

Since the implementation of the Corporate Recovery and Tax Incentives for Enterprises (Create) Act in 2021, various issues have surfaced due to its seemingly complex and vague provisions resulting to conflicting interpretations of certain provisions of the act, particularly on zero-rating of value-added tax (VAT), VAT refunds and tax incentives granted to registered business enterprises under the newly created Title XIII of the Tax Code, titled Tax Incentives. Some revenue issuances implementing the provisions of the Create Act were even amended on several occasions due to its conflicting provisions with the act itself and to address the concerns raised by various stakeholders.